ML090540063
| ML090540063 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 02/16/2009 |
| From: | Joseph Pacher Constellation Energy Nuclear Group, Ginna |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML090540063 (5) | |
Text
Joe Pacher Manager, Nuclear Engineering Services R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, New York 14519-9364 585.771.5208 585.771.3392 Fax joseph.pacher@constellation.com Constellation Energy Nuclear Generation Group February 16, 2009 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
SUBJECT:
Document Control Desk R.E. Ginna Nuclear Power Plant Docket No. 50-244 Fourth Interval Inservice Testing Program Submittal of 10 CFR 50.55a Request Number VR-14 Pursuant to 10 CFR 50.55a(a)(3)(i), R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) hereby requests NRC approval of the following request for the Fourth Interval Inservice Testing Program. Events leading to the request and a description of the proposed alternative are provided below.
Ginna LLC completed its most recent refueling outage in the spring of 2008. During a recent Inservice Testing Program assessment, it was determined that two safety injection accumulator pressure relief valves were inadvertently not added to the outage plan and consequently testing of the valves was not performed.
Plant shutdown conditions are required to access the relief valves, and the next refueling outage when plant conditions would permit the testing is scheduled to begin approximately six months after the end of the allowed test period. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), Ginna LLC hereby requests Nuclear Regulatory Commission (NRC) approval of an alternative to extend the test frequency so that inservice testing of the pressure relief valves can be performed during the R.E. Ginna fall 2009 refueling outage. Ginna LLC requests approval prior to April 3, 2009, which is the end of the allowed test frequency permitted by ASME OM code-1998 Appendix I, paragraph I-1360(a). The testing of these relief valves have been added to the forced outage scope as an interim compensatory measure.
The proposed alternative provides an acceptable level of quality and safety and is described in detail in the attached enclosure.
There are no regulatory commitments contained in this letter. Should you have questions regarding this matter, please contact David Wilson (585) 771-5219, or david.f.wilson@constellation.com.
? Ve truly yours,i seph E. Pacher 10 0C;ýOQ
Attachment:
10 CFR 50.55a REQUEST NO. VR-14 R. E. Ginna Nuclear Power Plant - Fourth Interval Inservice Testing Program Alternative for Relief Valve Test Interval Extension cc:
S.J. Collins, NRC D. V. Pickett, NRC Resident Inspector, NRC 10 CFR 50.55a REQUEST NO. VR-14 R. E. Ginna Nuclear Power Plant - Fourth Interval Inservice Testing Program Alternative for Relief Valve Test Interval Extension
10 CFR 50.55a REQUEST NO. VR-14 R. E. Ginna Nuclear Power Plant - Fourth Interval Inservice Testing Program Alternative for Relief Valve Test Interval Extension Proposed Alternative In Accordance with 10 CFR 50.55a (a)(3)(i)
-Alternative Provides Acceptable Level of Quality and Safety-
- 1. ASME Code Component(s) Affected The affected components are the R.E. Ginna Nuclear Plant's Safety Injection Accumulator relief valves 830A and 830B.
2. Applicable Code Edition and Addenda
American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code)Section XI, 1989 Edition, no Addenda. This edition refers directly to the ASME/ANSI OMa-1988 standard for valve testing (Part 10). Additionally, ASME OM code-1998 Appendix I is utilized for relief device testing.
3. Applicable Code Requirement
ASME OM code-1998 Appendix I, paragraph 1-1360(a), states that a minimum of 20% of the valves from each group shall be tested within any 48 month interval.
4. Reason for Request
R.E. Ginna has two pressure relief valves (830A and 830B) associated with the safety injection accumulators that make up Relief Device Group 8A. These valves can only be removed and tested during a refueling outage when the accumulators are depressurized. Both valves were last tested during the spring 2005 refueling outage. As there are only two valves in the Relief Device Group, one of the valves must be tested during each 48 month period per the Code. During a recent Inservice Testing Program assessment, it was determined that the two relief valves were inadvertently not added to the spring 2008 refueling outage plan and consequently testing of the valves was not performed. The current 48 month period for testing these valves ends on April 3, 2009.
The next R.E. Ginna refueling outage is currently scheduled to begin in September 2009, approximately six months after the end of the test frequency. This issue has been entered into the R.E. Ginna corrective action program.
5. Proposed Alternative and Basis for Use
The proposed alternative is to extend the test frequency as necessary to enable the required pressure relief test during the fall 2009 refueling outage, which is scheduled to Page 1 of 2
10 CFR 50.55a REQUEST NO. VR-14 R. E. Ginna Nuclear Power Plant - Fourth Interval Inservice Testing Program Alternative for Relief Valve Test Interval Extension begin approximately six months after the 48 month frequency required by paragraph I-1360(a). The test would then be performed when plant conditions allow access to the affected valves. The testing of these relief valves have been added to the forced outage scope as an interim compensatory measure.
The previous (4) periodic in-service tests (set pressure and seat tightness) for the subject valves dating back to 1993 have, with a single exception, been acceptable and within all Code and Owner established acceptance criteria. The single exception occurred on April 3, 2005 when relief valve 830A initially lifted outside the Code acceptance criteria of +/- 3
% of the set pressure value which is 800 psig. The lift occurred at 837 psig, 13 psig above the +3 % value of 824 psig. Subsequent disassembly of the valve revealed that a portion of the soft internal part (disc assembly o-ring) had shifted which caused the valve to initially stick and then lift above its allowable high end set pressure. The valve was subsequently rebuilt with a new o-ring installed on the disc assembly and satisfactorily passed its post-maintenance seat tightness and set pressure tests. This condition was considered to be a one-time anomaly and did not impact the overpressure protection of the accumulator.
Based on the above, R.E. Ginna concludes that completion of the pressure test prior to startup from fall 2009 refueling outage would provide an acceptable level of quality and safety.
6. Duration of Proposed Alternative
The duration of the proposed alternative is from April 3, 2009 until one of the valves is tested during the fall 2009 refueling outage (approximately September 30, 2009).
- 8. References
- 1. ASME Boiler and Pressure Vessel Code, Section Xl, 1989 Edition