L-98-243, Forwards Response to 980803 Telcon RAI Re Relief Request Submitted with Third Interval IST Program, . Modified & New Relief Requests Encl
| ML17229A865 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 09/21/1998 |
| From: | Stall J FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| L-98-243, NUDOCS 9809240057 | |
| Download: ML17229A865 (47) | |
Text
!.'ij REGULA Y INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9809240057 DOC.DATE: 98/09/21 NOTARIZED: NO FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power
& Light Co.
50-389 St. Lucie Plant, Unit 2, Florida Power
&, Light Co.
AUTH.NEGATE AUTHOR AFFILIATION STALL,J.A.
Florida Power
&. Light Co.
RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)
DOCKET I 05000335 05000389
SUBJECT:
Forwards response to 980803 telcon RAI re relief request submitted with third interval IST program,dtd 980112.
Modified
&, new relief requests,encl.
DISTRIBUTION CODE: A047D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: OR Submittal: Inservice/Testing/Relief from ASME Code - GL-89-04 NOTES:
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Florida Power 5 Light Company, 6351 S. Ocean Orive, Jensen Beach, FL 34957 September 21, 1998 L-98-243 10 CFR 50.4 10 CFR 50.55a U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 RE:
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Inservice Test Program R
uest for Additional Information During an August 3, 1998, telephone call among Florida Power and Light Company (FPL), the NRC, and the NRC contractor Brookhaven National Laboratory (BNL), FPL was requested to supplement the request for relief submitted with the third interval Inservice Test (IST) Program.
The third interval IST Program was submitted by FPL letter L-98-5 dated January 12, 1998.
FPL has determined, pursuant to 10 CFR 50.55a (a)(3), that the proposed alternatives would provide an acceptable level of quality and safety or that compliance with the specified requirements would result in hardship or unusual difficultywithout a compensating increase in the level of quality and safety.
Attachment 1 provides the requested information. provides the relief requests modified in response to the NRC requests. provides new relief requests identified after the original submittal.
Please contact us ifthere are any questions regarding this submittal.
Very truly yours, J. A. Stall Vice President St. Lucie Plant Pg JAS/GRM Attachments cc:
Regional Administrator, Region II, USNRC Senior Resident In'spector, USNRC, St. Lucie Plant 9809240057 98092i PDR ADQCK 05000335 P
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 1 Page 1
ATTACHMENT1 Summary of St. Lucie responses to NRC Questions
N4 St.'Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 1 Page 2 Question No. 1 Relief Request numbers VR-08, 11, 14 and 15 request the use of disassembly/inspection (D/9 without a discussion of non-intrusive testing (NIT).
VR-08 V081130 and V08163, Steam Supply to 1C and 2C AFW Pump Turbines Relief Request VR-8 has been withdrawn.
VR-11 V09303 (Unit 2), V09304, and V09305, 1A, 1B, and 1C AFW Pump Minimum Flow Recirculation Check Valves.
The relief request is revised to further explain the impracticality of performing NITduring system periodic testing due to inherent system design features.
VR-14 V07119 and V07120, RWT Discharge to SI pumps The relief request is revised to further explain the impracticality of performing NIT during system periodic testing due to system and valve design considerations.
VR-15 V07269 and V07270, Containment Spray Discharge Through NaOH Eductors.
The relief request is revised to provide forperforming NIT during system periodic testing at refueling intervals or every two years.
Question No. 2 Relief Requests VR-08, 09 and 10 propose disassembly and inspection for certain check valves, however, a backflow test at cold shutdowns or refueling appears practical.
VR-08 V081130 and V08163, Steam Supply to 1C and 2C AFW Pump Turbines Relief Request VR-8 has been withdrawn.
St.'Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 1 Page 3 VR-09 V08372 and V08373, 1C AFW Pump Warm-up Line Check Valves Relief Request VR-9 has been withdrawn.
VR-10 Unit 1 MFW Header Isolation Check Valve The relief request is revised to further explain the difficulties with respect to performing reverse flow testing during shutdown periods.
Question No. 3 VR-17 proposes disassembly/inspection (D/Q without a partial flow test, which appears practical.
VR-17 V07192 and V07193, Containment Spray Discharge Header Check Valves This relief request is revised to further explain the impracticality of performing partial flow testing of these valves.
Question No. 4 In VR-19, the licensee states that it is impractical to test the containment vacuum breaker valves during power operation based on their location inside containment and the need for local access.
There is not sufficient information to support the basis for impracticality.
VR-19 V-25-20 and V-25-21, Containment Vacuum Breaker Check Valves The NRC staff agreed to investigate the commission's policy with respect to requiring primary containment entry during power operation for routine (non-critical) tests and inspections.
Should the staff decide that containment entry is insufficient grounds for impracticality, then St. Lucie willperform additional investigation with respect to health and safety concerns to justify our position.
St.'Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 1 Page 4 Question No. 5 In PR-OS, the licensee requests relief from the frequency response range for the hydrazine pumps.
They operate at 0.61 Hz and the vibration probe is rated to 4;5 Hz. They have provided no information that would support that these probes would adequately identify any pump problems or provide an alternate method ( e.g., oil analysis).
This request had previously been approved for an interim period, until August 1994, however, it does not appear that the licensee complied with the Code or resubmitted a request between 1994 and 1998.
PR-08 2A and 2B Hydrazine Injection Pumps This relief request is revised to include a new alternate testing proposal that eliminates vibration monitoring and includes manufacturer's recommendations for preventive maintenance-type checks and inspections.
Note that the relief request previously approved on an interim basis was revised and resubmitted in 1994 via PPL letter No. L-94-212 dated August 22, 1994, and we have not yet received a response.
Question No. 6 Relief Request VR-5 states that partial fiowtest of SIT discharge valves cannot be performed during normal operations via SIT to RWT drain via Penetration 41 because two manual isolation valves need to be opened.
This is incorrect for Unit two since the inside valves SE-03-2A and 2B are solenoid valves.
VR-5 V3215, V3225, V3235 and V3245, Safety Injection Tank Discharge Check Valves The relief request is provided with additional clarification.
r St.'Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 1 Page 5 Question No. 7 Relief Requests VR-5 and VR-6 allow either D/I or NIT of one valve each outage.
Should be NIT only as is addressed in NUREG/CP-0152, Proceedings oftI>efiftlr,NRC/ASM'ymposium on Valve and Pump Testing.
V3215, V3225, V3235 and V3245, Safety Injection Tank Discharge Check Valves V3217, V3227, V3237 and V3247, Safety Injection Header Check Valves The bases for these relief requests are clarified and additional justification provided.
The St. Lucie position is that, as stated in Generic Letter 89-04, NUREG-1482, and OM-Code, Paragraph 4.3.2.4[c], disassembly and inspection is equivalent to and an acceptable alternative to flow testing check valves.
St.'Lucio Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 1
ATTACHMENT2 Revised Inservice Testing Program Relief Requests
.f, St. Lucio Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 2 APPENDIXA
.PUMP PROGRAM RELIEF RE UESTS (Page XXof XX)
RELIEF REQUEST NO. PR-08 COMPOM~22lTS Hydrazine Pumps 2A and 2B (2998-G-088, Sh 1)
PART 6 RE UIRK2KNT Pressure, flow rate, and vibration (displacement or velocity) shall be determined and compared with the corresponding reference values.
(Paragraph 5.2(d))
BASIS FOR RELIEF The hydrazine pumps are characterized as metering pumps operating at extremely slow speed (approximately 39 rpm). This equates to a rotational frequency of 0.65 Hz. In accordance with the Code, the required low limitof the frequency response for the vibration instruments would be one third of this or 0.21 Hz. Portable instruments satisfying this requirement are commercially unavailable. The low frequency vibration instrumentation presently in use at St.
Lucie is the Bentley Nevada model TK-81 with a 270 cpm probe.
The TK-81 integrator frequency response is essentially flat down to 120 cpm (cycles per minute) where the displayed output of the instrument slightly increases to approximately +1dB at 100 cpm.
The -3dB frequency response is reached at approximately 54 cpm. The velocity probe used with the TK-81 is a special low frequency probe nominally rated down to 270 cpm (-3 dB).
For this reason, vibration readings taken, even with the low frequency probe, are essentially meaningless and of no value in identifying degradation of these pumps.
Furthermore, the classical analysis of rotating components upon which the Code is based is not readily adaptable to slow moving components such as are installed in these pumps.
These pumps are standby pumps and little degradation is expected with respect to vibration performance between testing periods. The mechanisms of wear and degradation of rotating machinery are time and cycle dependant and, in this case, the number of repetitive wearing actions (cycles) is small both in frequency and absolute numbers.
The pumps cycle approximately 2220 times per hour and operation is typically limited to 1-2 hours per ~ear.
Thus, the probability of any significant pump deterioration over the plant's lifetime is extremely small. Note that these pumps are designed and built for continuous operation.
St. Lucio Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 3 APPENDIX A PUMP PROGRAM RELIEF RE UESTS (Page XXofXX)
RELIEF RE UEST NO. PR-08 (continued)
ALTERNATETESTING In lieu of measuring pump vibration, these pumps willbe maintained and inspected in accordance with the St. Lucie Preventative Maintenance Program that reflects the recommendations of the pump's manufacturer (Union Pump Co.). This Program willat a minimum, include periodic changing of the crankcase lubricating oil and oil analyses to identify significant wearing of internals.
This program is adequate for determining pump degradation that could impact operability and reliability.
yt
C.
St.'Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 4 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXof XX)
RELIEF RE UEST NO. VR-05 SYSTEM Safety Injection (2998-G-078, Sh 132; 8770-G-078, Sh 131B)
COMPONENTS V3215 V3225 V3235 V3245 CATEGORY FUNCTION These valves open to provide flowpaths from the respective safety injection tanks (SIT) to the reactor coolant system (RCS) and close to isolate the tanks from the high pressure of the RCS and the safety injection headers providing RCS integrity and preventing diversion of safety injection flow.
PART 10 RE Check valves shall be exercised nominally every 3 months, except as provided by Paragraphs 4.3.2.2,4.3.2.3,4.3.2.4and4.3.2.5.
(Paragraph4.3.2)
As an alternative to the testing in (a) or (b) above, disassembly every refueling outage to determine operability of check valves may be used.
(Paragraph 4.3.2.4(c))
L St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 5 BASIS FOR RELIEF APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXof XX)
RELIEF RE UEST NO. VR-05 (continued)
These are simple check valves with no external means of exercising or for determining disc position.
Consequently, the only practical method for stroke testing of the SIT discharge check valves is to discharge the contents of the SIT to the RCS.
Performing a fullflow test of the SIT discharge check valves during any plant operating mode is impractical because the maximum flowrates attainable by discharging the contents of the SIT to the RCS cannot meet the valves'aximum required accident condition flowrate as required by Generic Letter 89-04, Position 1. The maximum flowrate achievable during an SIT discharge test is restricted by the long stroke time of the SIT discharge isolation valves - motor-operated valves with a nominal stroke time of 52 seconds and limitations on SIT pressure during testing.
Under large break LOCA accident conditions, the maximum (peak) flowrate through these valves would be approximately 20,000 gpm as compared to typical test values of approximately 8,000 gpm.
Although the flowrate attained during these SIT discharge tests does not qualify as "fullflow",
it is sufficient to fully stroke the check valve discs to their fullyopen position. Verification of this is possible using non-intrusive testing techniques.
Due to system configuration, however, full-stroke exercising of the SIT discharge check valves cannot be performed in any plant operating mode other than refueling when the reactor vessel head is removed.
The SIT discharge check valves are identical with respect to size and design and they are installed in essentially identical orientations exposed to similar operating conditions.
Each has been disassembled and inspected several times during previous refueling outages with no abnormal wear or deterioration noted.
Additionally, PPL has reviewed the operating and maintenance history of similar valves used throughout the industry under comparable conditions.
Based on these reviews and inspections, there has been no evidence of valve degradation with respect to their ability to open and satisfactorily pass the required flow needed to fulfilltheir safety function. This along with the observation that the SIT flowrate and pressure drop traces obtained during the 1994 refueling outage testing are nearly identical, indicate that this baseline data was taken when each valve was in good working condition.
'E St; Lucio Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 6 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXof XX)
RELIEF RE UEST NO. VR-05 (continued)
BASIS FOR RELIEF (continued)
Since these valves are subjected to other testing and inspection requirements (other than flow testing) and related maintenance, there may be, from time to time, reason to disassemble a
valve that is also scheduled for non-intrusive testing. At such times there is no added gain in performing a flow test prior to the disassembly since the disassembly and visual inspection is adequate and in some respects superior to non-intrusive testing to confirm valve operability.
Thus, the additional cost and radiation exposure associated with performing the redundant non-intrusive testing cannot be justified. Note also that Generic Letter 89-04, OM-Code, Part 10, Paragraph 4.3.2.4(c), and NUREG-1482 state that disassembly and inspection is equivalent to and an acceptable alternative to flow testing.
Partial-stroke (open) of these valves requires discharging from the SIT to either the reactor coolant system (RCS) or the SIT drain header and RWT. Flow directed to the reactor coolant system during normal plant operation is impossible since the pressure in the SIT cannot overcome RCS pressure to establish flow. Verification of flow via the drain lines to the RWT requires opening two manual containment isolation valves for Unit 1 and an outside manual containment isolation valve and an inside solenoid-operated containment isolation valve for Unit 2. In both cases the potential risk of the loss of containment integrity in the event of an accident due to single active failure or dependence on operator action makes this unacceptable and impractical. (Reference NUREG-1482, Paragraph 3.1. 1)
In addition to flow testing, each valve is confirmed to be closed under cold shutdown conditions and is subjected to periodic leakage tests.
Note that, for this type ofvalve, the prescribed leakage testing is especially sensitive to internal valve degradation.
ALTERNATETESTING Each SIT discharge check valve willbe partial-stroke exercised at cold shutdown and full-stroked in the open direction during refueling outage by discharging all four SIT to the reactor vessel.
St. 'iucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 7 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXofXX)
RELIEF RE UEST NO. VR-05 (continued)
ALTERNATETESTING (continued)
Each SIT discharge check valve willbe verified closed and leakrate tested in accordance with Relief Request VR-04. During each refueling outage, under a sampling program on a rotating schedule, at least one of the check valves willbe non-intrusively tested to verify its disc fully strokes to its backstop.
In the event that a valve is scheduled for disassembly for reasons other that to satisfy this testing (e.g. regulatory action, preventative maintenance, corrective maintenance) then, in lieu of non-intrusive testing, the valve may be disassembled, inspected and manually stroked to verify operability.
Should a valve under testing or inspection be found to be inoperable and incapable of performing its function to open, then the remaining three valves willbe inspected or non-intrusively tested during the same outage, after which the rotational inspection schedule willbe reinitiated.
During activities associated with valve disassembly and inspection and prior to system closure, appropriate precautions willbe applied and inspections performed to ensure internal cleanliness standards are maintained and foreign materials are excluded from valve and system internals. These measures may include creating controlled work areas, maintaining a tool and equipment accounting system, installation of covers during non-work periods and final close-out inspections.
Following any valve reassembly, forward fiow operation of the valves (partial stroke open test) willbe observed.
This alternative testing as outlined is consistent with the requirements and recommendations of NRC Generic Letter 89-04, Position 1 and NUTMEG-1482, Guidelines forInservi ce Testing at Nuclear Power Plants, Paragraph 4.1,2.
St.'Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 8 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXofXX)
RELIEF RE VEST NO. VR-06 SYSTEM Safety Injection (2998-G-078 Sh 132; 8770-G-078 Sh 131B)
COMPOMi22ITS V3217 V3227 V3237 V3247 CATEGORY FUNCTION These valves open to provide flowpaths from the safety injection headers to the reactor coolant system (RCS) and close to isolate the headers from the high pressure of the RCS.
PART 10 RE UIREND<WT Check valves shall be exercised nominally every 3 months, except as provided by Paragraphs 4.3.2.2,4.3.2.3,4.3.2.4,and4.3.2.5.
(Paragraph4.3.2)
As an alternative to the testing in (a) or (b) above, disassembly every refueling outage to determine operability of check valves may be used.
(Paragraph 4.3.2.4(c))
BASIS FOR RELIEF These are simple check valves with no external means of exercising nor determining disc position.
Consequently, the only practical method for stroke testing of these check valves is by injection via the safety injection pumps or discharging the contents of the safety injection tank (SIT) to the RCS.
~~l St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 9 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXofXX)
RELIEF RE UEST NO. VR-06 BASIS FOR RELIEF (continued)
During plant operations at power, partial flow exercising these valves is not practical because neither the SIT nor the safety injection pumps are capable of overcoming reactor coolant system pressure.
Performing a full-flowtest of these check valves by SIT discharge is impractical because the maximum flowrates attained by discharging the contents of the SIT to the RCS do not meet the valves'aximum required accident condition flow as required by Generic Letter 89-04, Position 1. The maximum flowrate achievable during an SIT discharge test is restricted by the long stroke time of the SIT discharge isolation valve. This is based on the motor-operated valves nominal stroke time of 52 seconds and limitations on SIT pressure during testing.
Under large break LOCA accident conditions, the maximum (peak) flowrate through these valves would be approximately 20,000 gpm as compared to test values of approximately 8,000 gpm.
Note also that normal shutdown cooling system flow is incapable of fullstroking these valves based on the requirements of Generic Letter 89-04.
Although the flowrate attained during these SIT discharge tests does not qualify as "fullflow,"
it is sufficient to fully stroke the check valve discs to the fullyopen position and verification of this is practical using non-intrusive testing techniques.
Due to system configuration, however, full-stroke exercising of the SIT discharge check valves cannot be performed in any plant mode other than refueling shutdown when the reactor vessel head is removed.
The safety injection header check valves are identical with respect to size and design, and they are installed in essentially identical orientations exposed to similar operating conditions.
Each has been disassembled and inspected several times during previous refueling outages with no abnormal wear or deterioration noted.
PPL has additionaHy reviewed the operating and maintenance history of similar valves used throughout the industry under comparable conditions.
Based on these reviews and inspections, there has been no evidence ofvalve degradation with respect to their ability to open and satisfactorily pass the required flow needed to fulfilltheir safety function. This, along with the observation that the SIT flowrate and pressure drop traces obtained during the 1994 refueling outage testing are nearly identical, indicate that this baseline data was taken when each valve was in similar good working condition.
y7
ai, St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 10 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXof XX)
RELIEF RE VEST NO. VR-06 (continued)
BASIS FOR RELIEF (continued)
Since these valves are subjected to other testing and inspection requirements (other than flow testing) and related maintenance, there may be, from time to time, reason to disassemble a
valve that is scheduled for non-intrusive testing. At such times, there is no added gain in performing a flow test prior to the disassembly since the disassembly and visual inspection is adequate and, in some respects, superior to non-intrusive testing to confirm valve operability.
Thus, the additional cost and radiation exposure associated with performing the redundant non-intrusive testing cannot be justified. Note that Generic Letter 89-04, OM-Code, Part 10, Paragraph 4.3.2.4(c) and NUTMEG-1482 state that disassembly and inspection is equivalent to and an acceptable alternative to flow testing.
In addition to flow testing, each valve is confirmed to be closed under cold shutdown conditions and is subjected to periodic leakage tests.
Note that, for this type of valve, leakage testing is especially sensitive to internal valve degradation.
ALTERNATETESTING Each safety injection header check valve willbe partial-stroke exercised at cold shutdown and full-stroke exercised in the open direction during refueling outages by discharging all four SIT to the reactor vessel.
Each safety injection header check valve willbe verified closed and leakrate tested in accordance with Relief Request VR-04. During each refueling outage, under a sampling program on a rotating schedule, at least one of the check valves willbe non-intrusively tested to verify its disc fully strokes to its backstop.
In the event that a valve is scheduled for disassembly for reasons other than to satisfy this testing (e.g. regulatory action, preventative maintenance, corrective maintenance),
then, in lieu of non-intrusive testing, the valve may be disassembled, inspected, and manually stroked to verify operability.
~ \\
St. t.ucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 11 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXof XX)
RELIEF RE UEST NO. VR-06 (continued)
ALTERNATETESTING (continued)
Should a valve under testing or inspection be found to be inoperable and incapable of performing its function to open, then the remaining three valves willbe inspected or non-intrusively tested during the same outage, after which, the rotational inspection schedule will be reinitiated.
During activities associated with valve disassembly and inspection and prior to system closure, appropriate precautions willbe applied and inspections performed to ensure internal cleanliness standards are maintained and foreign materials are excluded from valve and system internals. These measures may include creating controlled work areas, maintaining a tool and equipment accounting system, installation of covers during non-work periods, and final close-out inspections.
Following any valve reassembly, forward flow operation of the valves (partial stroke open test) willbe observed.
This alternative testing, as outlined, is consistent with the requirements and recommendations of NRC Generic Letter 89-04, Position 1 and NUREG-1482, "Guidelines for Inservice Testing at Nuclear Power Plants," Paragraph 4.1.2.
St. Lucic Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 12 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXofXX)
RELIEF RE UEST NO. VR-08 (DELETED)
St. Lucio Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 13 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXofXX)
RELIEF REQUEST NO. VR-09 (DELETED)
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. ~
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St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attaclnnent 2 Page 14 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXofXX)
RELIEF RE UEST NO. VR-10 SYSTEM Feedwater System (8770-G-080, Sh 3)
COMPONENTS V09248 V09280 CATEGORY FUNCTION These valves close to isolate the respective steam generator to ensure adequate inventory of condensate for auxiliary feedwater pump operation.
PART 10 RE UIREIMENT Check valves shall be exercised nominally every 3 months, except as provided by Paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5.
(Paragraph 4.3.2)
As an alternative to the testing in (a) or (b) above, disassembly every refueling outage to determine operability of check valves may be used.
(Paragraph 4.3.2.4(c))
BASIS FOR RELIEF These are simple check valves with no external means of exercising nor determining disk position.
Consequently, the only practical method for determining disk position (close) is by performing a differential pressure back-leakage test.
Due to system configuration, there is no practical way of reliably performing such a test during ~an operational mode.
Under steaming conditions at power, isolation of the feedwater supply piping is not possible without causing a severe plant transient.
Under shutdown conditions, backflow testing would require draining a significant portion of the upstream feedwater piping and attempting to seat the subject valves by injection of water through the associated 1-inch downstream drain valves. Itis highly unlikely that such a test could be performed successfully and conclusively.
St. j.ucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 15 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXof XX)
RELIEF RE UEST NO. VR-10 (continued)
ALTERNATETESTING During each reactor refueling outage, at least one of these valves willbe disassembled, inspected, and manually stroked to verify closure capability.
Should a valve under inspection be found to be inoperable, then the other valve willbe inspected during the same outage, after which the rotational inspection schedule willbe reinitiated. During activities associated with valve disassembly and inspection and prior to system closure, appropriate precautions willbe applied and inspections performed to ensure internal cleanliness standards are maintained and foreign materials are excluded from valve and system internals.
These measures may include creating controlled work areas, maintaining a tool and equipment accounting system, installation of covers during non-work periods, and final close-out inspections.
This alternate testing agrees with the guidelines of NRC Generic Letter 89-04, Position 2 and as such, is considered to be approved upon submittal.
St. Lucio Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attaclunent 2 Page 16 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXof XX)
RELIEF RE UEST NO. VR-11 SYSTEM Feedwater System (2998-G-080, Sh 2B; 8770-G-080, Sh 4)
COMPONENTS V09303 (Unit 2 only)
V09304 V09305 CATEGORY FUNCTION These valves open to provide flowpaths from each auxiliary feedwater pumps'ischarge to the condensate storage tank to ensure adequate pump cooling during low flow conditions.
PART 10 RE UIRjEMENT Check valves shall be exercised nominally every 3 months, except as provided by Paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5.
(Paragraph 4.3.2)
As an alternative to the testing in (a) or (b) above, disassembly every refueling outage to determine operability of check valves may be used.
(Paragraph 4.3.2.4(c))
BASIS FOR RELIEF These are simple check valves with no external means of exercising nor determining disk position.
Consequently, the only practical method for determining disk position (open) is by performing a pump flowrate test. Full stroke capability must then be verified, per Generic Letter 89-04, Position 1, by attaining the maximum accident flowrate through each valve.
There is no flowrate instrumentation available to verify valve full-stroke exercising of these valves as required by the Generic Letter.
St. Lncie Units 1 and 2
~
Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 17 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page 26 of 44)
RELIEF RE UEST NO. VR-11 (continued)
BASIS FOR RELIEF (continued)
The lines in which these valves are installed are provided with permanent orifices that restrict the flowrate such that the maximum flow possible is insufficient to fullyopen these valves.
For this reason, non-intrusive testing would be ineffective and inconclusive and thus is not practical.
The associated auxiliary feedwater pumps are normally idle in standby status operated only during test periods, thus these valves see little service and service-related failures are unlikely.
ALTERNATETESTING During quarterly pump testing each of these valves willbe partial-stroke exercised via recirculation through the minimum flow test circuits with no flow measurements.
During each reactor refueling outage, at least one of these valves willbe disassembled, inspected and manually stroked to verify operability.
Should a valve or valves under inspection be found to be inoperable, then the other valve or valves in that unit willbe inspected during the same outage, after which the rotational inspection schedule willbe reinitiated. During activities associated with valve disassembly and inspection and prior to system closure, appropriate precautions willbe applied and inspections performed to ensure internal cleanliness standards are maintained and foreign materials are excluded from valve and system internals. These measures may include creating controlled work areas, maintaining a tool and equipment accounting system, installation of covers during non-work periods, and final close-out inspections.
Following reassembly, each valve willbe partial-flow exercised to verify operability.
This alternate testing agrees with the guidelines of NRC Generic Letter 89-04, Position 2 and as such, is considered to be approved upon submittal.
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 18 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXof XX)
RELIEF RE UEST NO. VR-14 SYSTEM Containment Spray (2998-G-088, Sh 1; 8770-6-088, Sh 1)
COMPONENTS V07119 V07120 CATEGORY FUNCTION These valves open to provide flowpaths from the refueling water tanks (RWT) to the containment spray and safety injection suction headers.
They close to prevent the transfer of containment sump water back to the associated RWT after a recirculation actuation signal (RAS) ~
PART 10 RE UIRKVIENT Check valves shall be exercised nominally every 3 months, except as provided by Paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5.
(Paragraph 4.3.2)
As an alternative to the testing in (a) or (b) above, disassembly every refueling outage to determine operability of check valves may be used.
(Paragraph 4.3.2.4(c))
C St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-9S-243 Attachment 2 Page 19 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXof XX)
RELIEF RE UEST NO. VR-14 (continued)
BASIS FOR RELIEF These are simple check valves with no external means of exercising nor determining obturator position.
Full-stroke exercising (open) of these valves would require the simultaneous operation of one high pressure safety injection (HPSI) pump, one low pressure safety injection (LPSI) pump, and one containment spray pump to verify that each valve can pass the maximum design accident flow. Such a test is not practical during any plant operational mode.
Non-intrusive testing (NIT) of these valves necessarily requires that each valve undergo a fullstroke cycle induced by flow through the associated piping. In this case, the maximum flowrate possible in the line is approximately 4,500 gpm the nominal design flowrate of the LPSI pumps. At this flowrate, taking into consideration that these 24-inch NPS valves are on the suction side of the pumps and not subjected to a starting pressure surge at the pump discharge; they willnot travel to the full-open position with a backstop impact when the associated LPSI pump is started or running.
This precludes any meaningful, reliable, and conclusive non-intrusive testing.
These are large valves (24-inch NPS) where disassembly is difficultand consumes a considerable amount ofplant resources, thus disassembly of both of these valves during each reactor refueling would pose a significant hardship and, based on plant safety considerations, is not warranted.
In addition, access for disassembly requires draining a significant portion of the safety injection system piping creating a significant and unnecessary load on the plant's radwaste processing systems.
The valves in each unit are identical with the same manufacturer, size, model designation, orientation, and service conditions.
ALTERNATETESTING During quarterly pump testing, each of these valves willbe partial-stroke exercised via recirculation through the minimum flow test circuits of the various safety injection systems.
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 20 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXof XX)
RELIEF RE VEST NO. VR-14 (continued)
ALTI<WNATETESTING (continued)
During each reactor refueling outage, at least one of these valves willbe disassembled, inspected, and manually stroked to verify operability.
Should a valve under inspection be found to be inoperable, then the other valve willbe inspected during the same outage, after which the rotational inspection schedule willbe reinitiated. During activities associated with valve disassembly and inspection and prior to system closure, appropriate precautions willbe applied and inspections performed to ensure internal cleanliness standards are maintained and foreign materials are excluded from valve and system internals. These measures may include creating controHed work areas, maintaining a tool and equipment accounting system, installation of covers during non-work periods, and final close-out inspections.
Following reassembly, each valve willbe partial-flow exercised open and tested closed to verify operability.
This alternate testing agrees with the guidelines of NRC Generic Letter 89-04, Position 2 and with related comments and recommendations in NUREG-1482, Appendix A.
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St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 21 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXofXX)
RELIEF RE UEST NO. VR-15 SYSTEM Containment Spray (8770-G-088, Sh 1)
COMPONENTS V07269 V07270 CATEGORY FUNCTION These valves open to provide flowpaths from the respective containment spray discharge headers to the spray additive eductors.
This flow through the eductors provides the motive force needed to inject the sodium hydroxide solution into the suction of the containment spray pumps.
PART 10 RE UIREMIUVT Check valves shall be exercised nominally every 3 months, except as provided by Paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5.
(Paragraph 4.3.2)
BASIS FOR RELIEF These are simple check valves with no external means of exercising or determining obturator position.
They cannot be fullflow exercised during normal operation since there is no flowrate instrumentation available to verify valve full-stroke exercising as required by Generic Letter 89-04, Position 1.
Note, these valves remain closed in a benign medium under all but testing and accident conditions and see little actual operation, thus service related failure is unlikely.
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 'Attachment 2 Page 22 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXofXX)
RELIEF RE UEST NO. VR-15 (continued)
BASIS FOR RELIEF (continued)
Each of these valves has been disassembled and inspected in the past and they have not displayed any indication of degradation that would impede their capability to perform their safety function to open.
These valves are identical with the same manufacturer, size, model designation, orientation, and service conditions.
The St. Lucie on-site staff does not have the resources required to perform non-intrusive testing of these valves, thus whenever non-intrusive testing is required, contract services must be procured.
For this reason, testing more frequently than once per refueling outage or two years is not practical.
ALTERNATETESTING During each reactor refueling outage or at least every two years, each of these valves willbe verified to fullyopen using non-intrusive techniques or other positive means.
St. Lucio Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 23 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXofXX)
RELIEF RE UEST NO. VR-17 SYSTEM Containment Spray (2998-G-088, Sh 2; 8770-G-088, Sh 2)
COMPONENTS V07192 V07193 CATEGORY FUNCTION These check valves open to provide flowpaths from the containment spray pumps to the containment spray headers in containment.
PART 10 RE UItu<22&lT Check valves shall be exercised nominally every 3 months, except as provided by Paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5.
(Paragraph 4.3.2)
As an alternative to the testing in (a) or (b) above, disassembly every refueling outage to determine operability of check valves may be used.
(Paragraph 4.3.2.4(c))
BASIS FOR RELIEF These are simple check valves with no external means of exercising or determining obturator position.
Exercising with system flow to the open position would require operating each containment spray pump at nominal accident flowrate.
Since no recirculation flowpath exists downstream of these valves, the only flowpath available for such a test would result in injecting radioactive-contaminated borated water into the containment spray headers and thence into the containment building via the spray nozzles.
Dousing personnel and equipment in this manner is obviously undesirable.
St. Lucio Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 2 Page 24 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXofXX)
RELIEF RE UEST NO. VR-17 (continued)
BASIS FOR RELIEF (continued)
Partial-flow testing using compressed air is possible, but requires draining the entire containment spray discharge header and supplying air via the 3-inch test connections.
The amount of air necessary for a meaningful test would require the temporary installation of an additional air compressor solely for this purpose.
The value of a partial-stroke air flow test for determining valve operability under these conditions is at best marginal and has littleor no merit; thus the burden ofperforming such a test is not warranted based on the limited value and benefit derived.
Each of these valves has been disassembled and inspected in the past, and they have not displayed any indication of degradation that would impede their capability to perform their safety function to open.
These valves are identical with the same manufacturer, size, model designation, orientation, and service conditions.
Note, these valves remain closed in a benign medium under all but accident conditions and see no actual operation, thus service related failure is unlikely.
ALTERNATETESTING During each reactor refueling outage at least one of these valves willbe disassembled, inspected, and manually exercised on a sequential and rotating schedule.
If, in the course of this inspection, a valve is found to be inoperable with respect to its function to fullyopen, then the other valve willbe inspected during the same outage.
During activities associated with valve disassembly and inspection and prior to system closure, appropriate precautions willbe applied and inspections performed to ensure internal cleanliness standards are maintained and foreign materials are excluded from valve and system internals.
These measures may include creating controlled work areas, maintaining a tool and equipment accounting system, installation of covers during non-work periods, and final close-out inspections.
This alternate testing agrees with the guidelines of NRC Generic Letter 89-04, Position 2 and agrees with related comments and recommendations in NUREG-1482, Appendix A.
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 3 Page 1
ATTACERVIENT3 NEW REQUESTS FOR RELIEF
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St. Lucie Units j. and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 3 Page 2 APPENDIX B RE UESTS FOR RELIEF - PUMPS (Page XXofXX)
RELIEF REQUEST NO. PR-12 COMPOMWTS Low Pressure Safety Injection Pumps 1A and 1B (8770-6-078, Sh 130B)
PART 6 RE UBQMF<22lT Ifdeviations fall within the alert range of Table 3, the frequency of testing specified in paragraph 5.1 shall be doubled until the cause of the deviation is determined and the condition corrected.
(Paragraph 6.1)
BASIS FOR RELIEF These pumps are tested quarterly under minimum flow conditions (less than 2 percent of nominal flow) using the minimum flow recirculation piping and, during each refueling, at nominal design flowrate. Note, the flowrate experienced during quarterly testing is considerably less than that expected during accident or normal operational conditions.
During the process of establishing new reference values for the quarterly tests related to implementation of the OM Code, it was discovered that the reference values for vibration for these pumps are near or exceed the absolute alert level of 0.325 in/sec. set forth in Table 3.
Using the IRD Model 810 w/ Model 970 Accelerometer Probe, the vibration levels at the pump bearings range between 0.28 and 0.38 in/sec.
Because of this, these pumps will perpetually remain in "alert" since when operating at low flow at least one of these readings typically exceeds the alert limitestablished by Table 3 (0.325 in/sec).
During the cold shutdown testing (substantial flow), vibration measurements are expected to be acceptable and well below the absolute alert limits of Table 3.
Due to the inherent design of the pumps, at low flows increased levels of vibration are induced as a consequence of energy dissipation and internal recirculation.
Spectral analyses and pump vibration signatures confirm that the increased levels of vibration experienced at low flows are in the frequency range of five times rotational frequency, and thus, are a function of impeller design.
In addition, there are significant levels of broad band vibration that is attributable to hydraulic instability. For this reason, it is clear that the increased vibration levels observed during low flow operation are, for the most part, unrelated to pump condition (degradation).
St. Lucio Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 3 Page 3 APPENDIX B RE UESTS FOR RELIEF - PUMPS (Page XXof XX)
RELIEF REQUEST NO. PR-12 (continued)
BASIS FOR RELIEF (continued)
ASMBOM Code-1995 and later revisions allow the classification of pumps into two groups, A and B, where the Group B pumps are those used for standby service, of which these pumps qualify. Recognizing that pump degradation that would manifest itself in increased vibration levels are not expected while a pump is in a standby mode, the code committee discontinued the requirement for quarterly vibration monitoring. This also reflects the growing concern of regulators and the members of the code committee that extended operation of pumps under minimum flow conditions has a deleterious effect on pump components.
Thus it is apparent that vibration monitoring in this case is insignificant and certainly does not warrant any increased frequency of testing as required by the Code.
The proposed alternate testing is adequate and appropriate, and is capable ofproperly monitoring pump operability as intended by the Code. It should be noted that more frequent testing of these pumps under minimum flow conditions for no justifiable reason does not add to plant safety and could have a significant negative impact on pump and system operability and reliability.
ALTERNATETESTING In conjunction with the quarterly testing of these pumps, vibration data willbe recorded per OM Code, Paragraphs 4.6.4 and 5.2.
Test results willbe evaluated, and the acceptance criteria of Table 3 applied with the exception that the minimum allowable vibration level defining the alert range willbe 0.500 in/sec.
Should measured vibration exceed 0.500 in./sec or 2.5V the subject pump willbe placed in "alert" status and the frequency of testing doubled until the cause of the deviation is determined and the condition corrected.
Should measured vibration exceed 0.700 in./sec or 6V the subject pump willbe declared inoperable until the cause of the deviation is determined and the condition corrected.
When these pumps are tested at substantial flow conditions (plant shutdown), the vibration acceptance criteria as shown in Table 3 willbe applied unconditionally.
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St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 3 Page 4 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXof XX)
RELIEF RE UEST NO. VR-21 SYSTEM Safety Injection System (2998-G-078, Sh 130A)
COMPONENTS V3102 V3103 CATEGORY FUNCTION These valves open to provide flowpaths from the high pressure safety injection pumps to the Refueling Water Tank (RWT) to provide for minimum flow through the respective pump in the event it is operating under low or no flow conditions.
rs PART 10 RE UIREMENT Check valves shall be exercised nominaHy every 3 months, except as provided by Paragraphs 4.3.2,2,4.3.2.3,4.3.2.4,and4.3.2.5.
(Paragraph4.3.2)
As an alternative to the testing in (a) or (b) above, disassembly every refueling outage to determine operability of check valves may be used.
(Paragraph 4.3.2.4(c))
~5 St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389
'0 L-98-243 Attachment 3 Page 5 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXof XX)
RELIEF RE UEST NO. VR-21 (continued)
BASIS FOR RELIEF These are simple check valves with no external means of exercising nor determining obturator position.
Consequently, the only practical method for determining disk position (open) is by performing a pump flowrate test. Full stxoke capability must be verified, per Generic Letter 89-04, Position 1, by attaining the maximum accident flow through each valve.
There is no installed flow measuring instrument available with which this determination can be made.
Non-intrusive verification of full-stroke operation is not practical since the system is provided with permanently installed orifices that restrict flow to a quantity less than that required to fullyopen the valves.
The associated high pressure safety injection pumps are normally idle in standby status and are operated only during test periods, thus these valves see little service and service-related failures are unlikely.
These valves are identical with the same manufacturer, size, model designation, orientation, and service conditions.
ALTERNATETESTING During quarterly pump testing each of these valves willbe partial-stroke exercised via recirculation thxough the minimum flow test circuits with no flow measurements.
During each reactor refueling outage, at least one of these valves willbe disassembled, inspected, and manually stroked to verify operability.
Should a valve under inspection be found to be inoperable, then the other valve willbe inspected during the same outage, after which the rotational inspection schedule willbe reinitiated.
During activities associated with valve disassembly and inspection and prior to system closure, appropriate precautions willbe applied and inspections performed to ensure internal cleanliness standards are maintained and foreign materials are excluded from valve and system internals. These measures may include creating controlled work areas, maintaining a tool and equipment accounting system, installation of covers during non-work periods, and final close-out inspections.
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 3 Page 6 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXofXX)
RELIEF RE UEST NO. VR-21
~ (continued)
ALTERNATETESTING (continued)
Following reassembly, each valve willbe partial-flow exercised open and tested closed to verify operability.
This alternate testing agrees with the guidelines of NRC Generic Letter 89-04, Position 2 and with related comments and recommendations in NUREG-1482, Appendix A.
St".Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 3 Page 7 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXof XX)
RELIEF RE UEST NO. VR-22 SYSTEM Chemical and Volume Control (2998-G-078, Sh 122, 8770-G-078, Sh 120B)
COMPONENTS V2435 CATEGORY FUNCTION These valves open to provide thermal reliefprotection for the Regenerative Heat Exchanger
. and related piping in the event that the charging header is isolated and hot fluid continues to flow through the tube side (letdown) of the Regenerative Heat Exchanger.
PART 10 RE UIRKVIENT Safety and relief valves shall meet the inservice test requirements of Part 1. (Paragraph 4.3.1)
BASIS FOR RELIEF These are spring-loaded check valves that are designed to open with a differential pressure of 250 psid while the "lifting"differential needed to protect the charging injection piping is 500 psid.
The opening setpoint (differential pressure) of these valves is a function of the valve design and construction, and is not readily adjustable, thus they are not considered true relief valves even though they serve that purpose.
Furthermore, they are welded in place in the system and cannot be removed for bench testing.
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St". Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 L-98-243 Attachment 3 Page 8 APPENDIX B RE UESTS FOR RELIEF - VALVES (Page XXofXX)
RELIEF RE UEST NO. VR-22 (continued)
BASIS FOR RELIEF (continued)
Performing the inspections and leakage testing, as described in Part 1, is not practical while the valves remain installed in the system.
Also, since these valves are not adjustable and accessible, the liftpressure cannot be accurately verified or set per Part 1-only functional adequacy can be confirmed.
The proposed functional adequacy test willprovide assurance the valves willsatisfactory perform their intended function.
ALTERNATETESTING On a quarterly basis, each of these valves willbe exercised to demonstrate they open with a differential pressure not to exceed 500 psig.