ML17264A740
| ML17264A740 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/14/1996 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Vissing G NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-M94509, NUDOCS 9611260207 | |
| Download: ML17264A740 (14) | |
Text
CATEGORY 1 REGULATO INFORMATION DISTRIBUTION
.STEM (RIDS) t ACCESSiOH',NBR:9611260207 DOC.DATE: 96/ll/14 NOTARIZED: NO FACIL:30'".24) Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G
AUTH.NANf:
AUTHOR AFFILIATION MECREDY,R.'1;..
Rochester Gas a Electric Corp.
RECI,P.NAME RECIPIENT AFFILIATION VISSING,g;-
DOCKET 05000244
SUBJECT:
Provides addi info in support of request for NRC approval of encl rev to valve testing relief requests VR-869,per 960528 ltr.
A T
05000244 E
NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
DISTRIBUTION CODE:
A047D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: OR Submittal: Inservice/Testing/Relief from ASME Code GL-89-04 RECIPIENT ID CODE/NAME PD1-1 LA VISSING,G.
INTERNAL: AEOD/SPD/RAB NRR/DE/EMEB OGC/HDS3 RES/DET/EMMEB EXTERNAL: LITCO ANDERSON
'NRC PDR COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
0 1
1 1
1 1
1 RECIPIENT ID CODE/NAME PD1-1 PD FILE JEST.EQ~
NUDOCS-'ABSTRACT RES/DET/EIB NOAC COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 D
0 NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)
ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED:
LTTR 13 ENCL 12
AND ROCHESTER GASANDELECTRIC CORPORATION
~ B9 EASTAVENLIE,ROCHESTER, N.Y. Id649-000I AREA CODE716 5'.2700 November 14, 1996 ROBERT C. MECREDY Hvcleor operations U.S. Nuclear Regulatory Commission Document Control Desk Attn:
Guy Vissing Project Directorate I-1 Wa'shington, D.C.
20555
Subject:
Inservice Testing (IST) 'Program for Pumps and Valves Revision to Relief Request VR-8&9 Third Interval (1990-1999),
Revision 2
Safety Injection Accumulator Check Valves R.E. Ginna Nuclear Power Plant Docket No. 50-244 Ref. (a):
Letter from Jocelyn A. Mitchell (NRC), to Dr. Robert C.
Mecredy (RG&E),
"Request for Relief from the American Society of Mechanical Engineers (ASME)
Code Section XI Requirements for R.E.
Ginna Nuclear Plant (TAC No.
M94509)," dated May 28, 1996.
Dear Mr. Vissing:
The purpose of this letter is to provide additional information in support of the request for NRC approval of the attached revision to valve testing relief requests-VR-8&9 (for check valves CV-842 A/B and CV-867 A/B) as discussed in the referenced letter.
The referenced letter granted a 1 year relief to allow for submittal of requested additional information and descriptions.
Granting of these relief requests would replace the current disassembly schedule of these check valves (two valves every six years) with a more frequent testing schedule (all four valves every 54 months) to be performed during plant refueling outages as provided for in ASME OMa Part 10 Section 4.2.
This request is made in accordance with the provisions of 10CFR50.55(a)(3)-(i) and (a)(3)(ii), in that the proposed alternatives provide an equivalent level of quality and safety due to the fact that the unique configuration and operating conditions of these valves. is such that they remain in excellent material condition, as documented in the inservice testing program history records.
In addition, the approval of these requests willresult in lower personnel radiation exposures, reductions in thermal cycling induced age degradation for both SI Accumulators, and a
reduction in probability of nitrogen gas injection into the RCS.
Unlike the system alignment in many other nuclear power plants, the Ginna Station combined accumulator and safety injection pump pathway is not designed as part of a normal flow path for other
,PJ plant systems.
This system's only purpose is to provide a pathway
, 9bi12b0207 9bii14
'PDR ADQCK 0SO00aee P
1 for safety injection to the RCS and has no flow path interfaces with other frequently active systems such as the residual heat removal system.
The only time that these check valves are cycled is during an actual safety injection condition, quarterly partial flow testing of 842 A/B, and periodic full flow testing.
Therefore, the valves are not subject to degradation mechanisms except during test conditions.
The periodic stroke testing also represents an abnormal/high risk condition that requires special procedural controls and results in additional schedule and resource impacts during plant cooldown transitions as shown by the attached "SI Accumulator Check Valve Full Flow Test" risk/cost impact assessment (Attachment 3).
Rochester Gas and Electric (RG&E) is an original and currently participating member in the nuclear industry check valve working group (NIC).
As
- such, RG&E has a well-documented maintenance history that has been analyzed as demonstrated by the attached matrix "SI Accumulator Discharge Check Valves 842A, 842B, 867A and 867B Disassembly/Inspection Results" (Attachment 4).
The matrix shows that after the first twenty years of operation, no degradation has occurred that adversely impacted the operability of these check valves.
A review of industry wide history documentation has shown that there has been only one degraded performance indication of the same check valve type and manufacturer.
As shown on the attached "Nuclear Plant Reliability Data
. System Failure Master Report" (Attachment 5) this degradation did not affect the system operability.
Furthermore, this valve was being use'd in the residual heat removal shutdown cooling mode which results in flow induced cycling and vibration wear mechanisms.
As discussed above, this is not applicable to Ginna for these valves
- and, therefore, the wear conditions are absent.
In order to allow proper planning for the fall 1997 Refueling
- Outage, we would appreciate a response by February 1997.
Very truly yours, Robert C. Mecred REJ4438 xc:
Mr. Guy Vissing (Mail Stop 14C7)
Project Directorate I-1 Nashington, D.C.
20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector
Attachment 1
RELIEF REQUEST NO.
VR 8 Rev.
1 SYSTEM:
VALVES CATEGORY:
SAFETY CLASS:
FUNCTION:
Safety Injection
- 842A, 842B A/C These valves open to provide flow from the safety injection (SI) accumulators to the reactor coolant system (RCS).
TEST REQUIREMENT:
Check valves shall be exercised at least once every three months except as provided by IWV-3522.
(IWV-3521)
If only limited operation is practical, during plant operation the check valve shall be part-stroke exercised during plant operation and full-stroke exercised during cold shutdowns.
(IWV-3522)
BASIS FOR RELIEF:
The previous relief request VR-8 provided for valve disassembly once every six years as the alternative position.
(Relief Request No.
VR-8)
Full-stroke open and close exercising during normal power operation cannot be accomplished since system pressures required to perform the test are not enough to overcome RCS pressure.
A test method that permits and confirms full-stroke exercising of'these check valves during cold shutdown has been developed for Ginna Station.
To perform the
- test, the plant must be maintained in an off-normal condition with a risk for nitrogen injection and possible entrainment in the RCS.
The performance of this test also involves added personnel radiological exposure.
Additionally, this test method requires extensive planning and setup and'ubstantially impacts refueling outage schedule at the start of the shutdown.
As a result of the implementation of this check valve test method, the need for periodic disassembly to satisfy Code requirements would no longer exist thereby eliminating the potential for improper reassembly.
The maintenance history of these check valves documents that the valves have been found in excellent mechanical condition
~
RELIEF REQUEST NO.
VR 8 Rev.
1 CONT upon disassembly.
,With an excellent mechanical condition baseline verified by periodic part-stroke (quarterly) and full-stroke testing, the operability of check valves 842A and 842B will continue to be ensured.
ALTERNATE TESTING:
These valves will be part-stroke exercised quarterly using the SI test header.
Full-stroke exercising of 842A and 842B will be performed in conjunction with full-stroke exercising of 867A and 867B at a frequency of once every three refueling outages.
Attachment 2
RELIEF REQUEST NO.
VR 9 Rev.
1 SYSTEM:
VALVES:
CATEGORY:
SAFETY CLASS:
FUNCTION:
TEST REQUIREMENT:
Safety Injection
- 867A, 867B A/C 1
These valves open to provide a flowpath from the safety injection (SI) accumulators or the SI pumps to the reactor coolant system (RCS) cold legs.
Check valves shall be exercised at least once every three months except as provided by IWV-3522.
(IWV-3521)
If only limited operation is practical, during plant operation the check valve shall be part-stroke exercised during plant operation and full-stroke exercised during cold shutdowns.
(IWV-3522)
The previous relief request VR-9 provided for valve disassembly once every six years as the alternative position (Relief Request No. VR-9)
BASIS FOR RELIEF:
Full-stroke or part-stroke open and close exercising during normal power operation cannot be accomplished since system pressures required to perform the test are not enough to overcome RCS pressure.
A test method that permits and confirms full-stroke exercising of these check valves during cold shutdown has been developed for Ginna Station.
To perform the test, the plant must be maintained in an off-normal condition with a risk for nitrogen injection and possible entrainment in the RCS.
The performance of this test also involves added personnel radiological exposure.
Additionally, this test. method requires extensive planning and setup and substantially impacts refueling outage schedule at the start of the shutdown.
As a result of the implementation of this check valve test method, the need for periodic disassembly to satisfy Code requirements would no longer exist thereby eliminating the potential for improper reassembly.
The maintenance history of these
RELIEF REQUEST NO.
VR 9 Rev.
1 CONT check valves documents that these valves are found in excellent mechanical condition upon disassembly.
With an excellent mechanical
'ondition baseline verified by periodic part-stroke and full-stroke. testing, the operability of check valves 867A and 867B will continue to be ensured.
ALTERNATE TESTING:
These valves will be part-stroke exercised each refueling outage using actual SI flow into the RCS.
Full-stroke exercising of 867A and 867B will be performed in conjunction with full-stroke exercising of 842A and 842B at a frequency of once every three refueling outages.
1 ATTACHMENT (3-Sl Accumulator Check Valve Full Flow Test 10/2466 The Sl Accumulator check valves 842A, 8428, 867A and 8678 require a quarterly exercise veriTication to satisfy ASME Sec XIrequirements.
RG &E has developed a test method to perform fullflowexercise testing of these check valves during refueling shutdowns.
o Oetermine the optimum frequency forfullflowexercise test performance based on achievement of assigned technical objectives and cost impact.
o Evaluate test frequency options for testing by constraint determination; including weighted value assignment to technical objectives and cost.
o Compare test frequency options rehtionships; including CostlBenefit, Advantagesl Oisadvantages and Risk.
Two (2) test frequency options forcheck valve fullfhwtest performance are:
- 1) Perform fullflowexercise test of each check valve once every 54 months.
- 2) Perform fullflowexercise test of each check valve once every 18 months.
Cost / Benefit dvan-/Disadvanta es gOpttons 2 100 g 100 Risk 0
50 Lo Benefit 0
50 100 Lo Advantages Hi
>o o
0 working within given constraints.
It achieved the best overall evaluation using weighted values on achieving technical objectives and comparitive relationships.
I vt" e
ATTACHMENT 3 Sl Accumulator Check Valve Full Flow Test Evaluation of the fotlowtr>g (2) proposed options for Sl accumulator dischargo chock valves, 842A, 8428, 867A and 8678.
Opgon 1: porfonn fullliowexercise test of each Sl accumulator chock valvo once every 54 months.
Option 2: Perform fullUow exercise test of each SI accumu4tor chock valve once evo 18 months Achievement:low 1
... Hi h 10 Technical Ob ectives Maximize vatve(s) operability confidonce Minimize potonUat occurrenc.RRH pump NPSH loss Minimize potenUal occurrenco. N2 Ingross to RCS Minimize¹ of thermal shock cyclos to Accumulator Minlmlzo¹ of prossuro translonts to chock valvos Minimize unnoccessary wear of chock valve Minkntzo SIPE performance (Note 3)
Meets 6 year maximum operability vodlicatlon Intonral as lnforrod by NRC Generic Letter 854)4, Position 2 W@I ht 10 10 10 10 10 g~<cc~c, Kara>c!>vlcc xwmuvgP"c. le>>>vwvb>.:>>Sc ><Pea<vf
'" "n ""'
W"" pM~>~>Nm~~@ccs>r>Ycavv&iv.'k"i>.%44 Porcont of Highest Value ccccccuew>ac<vcr';c.v<1;rK rurcu,><< >>>ex(. Vr>CV rcvrA><K<wv>>res pr...c v
)Psr>rs>wvr>uvuvct>s 'K%'<@6 Pri >err'rreco,. N roc WA r c
'r><%su<br~< wv'Yr 100.0'CI>
48.64k Coat
$K Over Three Year Period Noto 1 Tost PreparaUon/RestoraUon (64 manhours por tost)(Noto 4)
SIPE Training (100 manhours por tost)
(Note 4)
Dose ($10,000/Rem)
Outage Schodule Impact (Delay of Shutdown/Cooldown Proc 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />s/tost 6 $333,000/
~v'u vE vuc>urrru
< >.'Kcce<crA>Sr>SC >Pcuvr>'r>>v KCS war>vurKya "s c <<v Ku+
...;Ca>< >A'c>> 'Cvu>.cc 'waÃcv5> (4Q Hvavrvu rr>>s >:wwc<
>oN< >av Percent above Lowest Cost Pe<coot bebvv Kigr>est Cost 2560 4000 600 111000 7680 12000 1800 333000 ay) 3g>?g>+~/P~c+<g r~>'@!1,18160 (','vcr354w80 j~'1'j<'".".'~,'~ "~;">>'.v < 'v:sj 0.0%
200.0%
~.7%
O.ms EValuatjon 70%TCCh/30%'CO'St/."':c",~:"~X~g-~"~j-:~+~NOte',:2'/a "sw "A ms'I:4M
- 2. Tho largest value Indicates tho most attractive rocommondatlon.
- 3. SIPE ~ SlgnNcant infrequently Performed EvotuUon
- 4. Personnel cost sc $40/manhour Rw+tj 'u>
huf
'u.>>>wA>>
r, ~e>vurA>vggS)p,cs><r sc sp
<e>>c.> >>>Ave~'Kr Evaluato: hw 10... Hi h 100
>'.7>4<s<ace 1
2 100.0 100.0 48.6 Advantagos Disadvantages 100.0 Risk Probability Risk Impact 5
6
- 1. Re8octs the rotaUvo cost.
- 2. Reflects tho achlovement oftho technical objoctivos.
- 3. Roitocts the achlovomont of tho technical objoctivos.
- 4. Intangabies, futuro costs of porsonnol and training.
- 5. Probability: Catastrophic failure of valve/system.
- 6. Impact, lo. Outage Schodulo, valve dogradation
- ".,";,'-.. ';
- :,':&:,-::,,!,:Componeiit:;:;.".",:";.-:::;:;.':-."
Body/Bonnet Bolts/Studs Body/Bonnet Nuts No Abnormalities Found.
Fair Minor Corrosion Present Good Satisfactory'atisfactory Slight Erosion Slight Erosion Retaining Block Studs Retaining Block Nuts No Apparent Thread Degradation Threadl Good, Flats Welded and Ground Good Acceptable Satisfactory Body Seat Good Service Condition Satisfactory Acceptable Disc Retaining Blocks, Clapper Arm & Shaft Disc Trunnion Bushing Body/Bonnet Gasket Seating Surface Bonnet Gasket Surface Body Contact/Sealing Area Blue Check Disc/Seat Contact/Sealing Area Blue Check Freedom of Movement Good Service Condition, No Apparent Wear No Wear or Damage No Apparent Warpage Usable Surface Condition Minor Surface Wear No Signs of Leakage, Pitting or Washout No Signs of Leakage, Pitting or Washout Satisfactory, 360'ontact Satisfactory, 360'ontact Acceptable Satisfactory, Minor Wear No Wear or Damage No Apparent Warpage Satisfactory No Wear No Signs of Leakage, Pitting or Washout No Signs of Leakage, Pitting or Washout Satisfactory, 360'ontact Satisfactory, 360'ontact Acceptable Acceptable with Minor Indications, No Unusual Wear No Wear or Damage No Apparent Warpage Usable Surface Condition Minor Surface Wear No Signs of Leakage, Pitting or Washout No Signs of Leakage or Pitting. Slight Washout Satisfactory, 360'ontact Satisfactory, 360'ontact Acceptable Acceptable with Minor Indications, No Unusual Wear Minor Surface Scratches No Apparent Warpage Usable Surface Condition Normal Service Wear No Signs of Leakage, Pitting or Washout No Signs of Leakage or Pitting. Slight Washout Satisfactory, 360'ontact Satisfactory, 360'ontact Acceptable
- NPRGO6AA,
~TTAC~ 5 Nuclear Plant Relia~ty Data System
- Failure Haster Repoj t(w/Un
< Information>
By: Unit ID - value, System
- value Run Date 08/05/96 Job Nunber:
3566
~
~
ACCEPTAHCE DATE: 10/04/93 Utility.
.Pacific Gas and Electric Company Unit.
.DIABLO CANYON 2 NSSS.
.Mestinghouse Component....VALVE Util Component Id.....RHR ~ 2.8740A Discovery Date..10/15/91 Discovery Time..12:00 End Date..03/18/93 Input Date...08/03/93 Restoration Days......520 Severity Level.....K - Degraded Failure Node.......IL
- Internal Leakage Failure Detection..B
- Haintenance/I'est Fail Cause Cat.....H
- Age/Hormal Usage Fail/Cause Desc....BE
- Dirty BG - Corrosion System Effect......E
- System Function/Operation Unaffected Plant Effect.......G
- Resulted in No Significant Effect Corrective Action..AA - Recalibrate/Adjust Docunentation......N
- Other Documents or Records are Not Available LER Report Number..
System Affected....CFF
- Residual Heat Removal/l.p Safety Inject-M Failure Description Narrative.....
DURING REFUELING, WHILE PERFORHIHG LOCAL LEAK RATE TESTS, THE RESIDUAL HEAT REKOVAL SYSTEH DISCHARGE TO THE REACTOR COOLAHT SYSTEM HOT LEG LOOP 1
SECOND OFF CONTAINHEHT ISOLATION CHECK VALVE MAS FOUND MITH BACK I.EAKAGE PAST THE SEAT.'HE LEAK RATE MAS 2 5
GPH MHICH EXCEEDED THE 1
GPH TEST CRITERIA.
THE LOSS OF THE VALVEiS ISOLATION FUNCTION HAD NO EFFECT OH THE SYSTEH OR THE PLANT SINCE THE Cause of Failure Harrative.....
FIRST OFF CONTAINMENT ISOLATIOH VALVE PAST ITS TEST.
THE CAUSE OF THE FAILURE MAS AGE RELATED DIRT AND CORROSION PRODUCTS ON THE SEATS
~
Corrective Action Narrative.....
tHE VALVE SEATS MERE CLEANED.
THE VALVE MAS THEN TESTED AND RETURNED To SERVICE Safety Class........
S Data/Ccnaents 1.....
Data/Comnents 2.....
Data/Comnents 3.....
Data/Comncnts 4.....
Data/Comnents 5.....
Hanufacturer........
Anchor / Darling Valve Co Hfr Hodel ld........
Hfr Hodel Ho...
~ ~.. ~ S350MSC Hfr Serial No.......
NF Drawing No..........
108010 Engineering Codes
~ Typee
~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
A B.Operator..........
~.
'C.Function/Application DE Body Haterial.......
F.Nominal Inlet Size (
G.Size (Inlet).......
~
H.Haxiaam Design Press J.Haximan Design Tempe Check-Hech(Diff-Press Open/Sprn One-May Flow Austenitic Stnls Stl-304 4 to 11.99 IN 8.000 IH 0.000 PSIG 0.000 DEGF Application.........
Function............
System.........
~.... Residual Heat Removal/LP Safety Injec UtilitySystem......
10 Data Start Date..03/'l3/86 ln-Service Date......08/20/85 Accepted Date....02/17/88 Out-of-Service Date..
~:
~
~
W,IV ~
Ih
~
I4 t
~c/;
I,
/
c