ML060240354
| ML060240354 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 01/23/2006 |
| From: | Grecheck E Dominion Energy Kewaunee |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 05-891 | |
| Download: ML060240354 (5) | |
Text
1)otninion Energy Kewaunee, Inc.
WOO I)ominion Boulevard. G l e n Allen. VA 2 3060 January 23, 2006 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Serial No.05-891 KPS/LI C/GR:
R1 Docket No.
50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE, INC.
KEWAUNEE POWER STATION INSERVICE TESTING VALVE RELIEF REQUEST VRR-05 Pursuant to 10 CFR 50.55a(a)(3)(ii) Dominion Energy Kewaunee, Inc. (DEK) hereby requests Nuclear Regulatory Commission (NRC) approval of the following relief request for the Kewaunee Power Station (Kewaunee) fourth ten-year lnservice Testing Interval.
VRR-05:
SI-350A, -3508 Sump B Supply to RHR Isolation Valves Due to an extended forced outage in 2005, the start of the 2006 Kewaunee refueling outage was rescheduled from April 2006 to September 2006. The current relief request test interval will be exceeded on April 25, 2006. To prevent exceeding the current relief request test interval, DEK requests approval of this relief request by April 25, 2006. A similar relief request was previously approved for the Fourth Ten-Year Interval on March 4, 2005, (ADAMS Accession NO. ML050380305). This relief request would change the previously approved relief request by adding a 25% extension allowance to the test interval to provide scheduling flexibility. to this letter contains Kewaunee relief request VRR-05.
If you have any questions or require additional information, please contact Mr. Gerald Riste at (920) 388-8424.
Very truly yours, Eugene S. Grecheck Vice President-Nuclear Support Services Attachments:
- 1.
Valve Relief Request - VRR-05 Commitments made in this letter: None
Serial No.05-891 Docket No. 50-305 Page 2 of 2 cc:
Regional Administrator U. S. Nuclear Regulatory Commission Region Ill 2443 Warrenville Road Suite 210 Lisle, Illinois 60532-4352 Mr. D. H. Jaffe Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0-7-D-1 Washington, D. C. 20555 Mr. S. C. Burton NRC Senior Resident Inspector Kewaunee Power Station Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707 INSERVICE TESTING VALVE RELIEF REQUEST VRR-05 VALVE RELIEF REQUEST VRR-05 KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.
Serial No.05-891 Page 1 of 2 VALVE RELIEF REQUEST - VRR-05 System:
Safety Injection Valve (s) :
SI-350A, SI-350B Category:
B Function:
SI-350A and SI-350B are located within separate enclosures outside containment in the lines leading from containment sump "B" to the suction of the RHR pumps. The valves perform an active safety function in the open position. SI-350A&B must be capable of opening, by remote manual switch actuation, when transitioning from the injection mode of Safety Injection (SI) to sump recirculation for long-term core cooling. The valves also perform an active safety function in the closed position. SI-350A&B are designated containment isolation valves for penetrations 30W and 30E per USAR Table 5.2-2. The valves must be capable of closing by remote manual switch actuation to maintain containment integrity in the event a system malfunction occurs.
Code Requirement: Valves with remote position indicators shall be observed locally at least once every 2 years to verify that valve operation is accurately indicated. (ASME OM Code 1998 Edition with the 2000 Addenda)
(OMb Code 2000, ISTC-3700)
Alternate Testing:
For valves SI-350A and SI-350B, perform remote position indication verification on a 36-month frequency, +25% for scheduling flexibility. This verification will normally be performed coincident with preventative maintenance on the valve motor operators, which is scheduled on a 36-month +25% frequency. The 36-month +25%
frequency is based on past preventative maintenance and inspection results, and corresponds with every other 1 8-month refueling cycle. In addition, the valves will be leakage tested on a refueling outage frequency to ensure valve closure. These activities in conjunction with quarterly monitoring of valve stroke times will ensure reliable operation of the valves, including remote position indication.
Basis For Relief:
Pursuant to 10 CFR 50.55a(a)(3)(ii), relief is being requested on the basis that compliance with the specified requirements of the Code would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
These valves are containment isolation valves located outside of the containment building in separate enclosures. Local observation of the valves during the performance of position indication
Serial No.05-891 Page 2 of 2 verification requires disassembly and removal of the enclosures.
Subsequent to reassembly, the enclosures require leak testing.
The additional activities involved with this local observation are time consuming and performed in a Radiation Area. It is DEKs position that compliance with the 2-year Code requirement for local observation of valve position indication would result in a hardship without a compensating increase in the level of quality and safety.
Allowing a 25% extension follows Kewaunee Power Station Technical Specifications section 4.0, Surveillance Requirements.
Note: A similar relief request was approved for the Third 10-Year Interval via NRC Safety Evaluation dated July 1, 2004, and for the Fourth 10-Year Interval via NRC SE on March 4, 2005. The intent of that relief request was to allow the local observation of valve position indication to be performed coincident with preventative maintenance on the valve motor operators, which is scheduled on a 36-month frequency. Kewaunee administrative procedures apply a maximum allowable extension period of 25% of the specified maintenance interval to preventative maintenance activities, similar to that allowed by Technical Specifications 4.0.b for surveillance requirements. Approval of this relief request will allow the local observation of valve position indication and preventative maintenance to remain coincident with each other as intended.