ML18005A191
| ML18005A191 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/30/1987 |
| From: | Zimmerman S CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.1, TASK-TM NLS-87-234, NUDOCS 8711030429 | |
| Download: ML18005A191 (7) | |
Text
REGUL*
INFORMATION DISTRIBUTIO YSTEM (RIDS)
ACCESSION NBR: 8711030429 DOC. DATE: 87/10/30 NOTARIZED:
NO DOCKET ¹ FACIL: 50-400 Shearon Harris Nuclear Poeer Planti Unit 1> Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION ZIMMERMANiS. R.
Carolina Poeer 8c Light Co.
RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Contra)
Desk)
SUBJECT:
Submits supp 1 to in-ser vice pump 5 valve testing program per 10CFR50. 55a(g ) (5)
- 8. requests that expedited relief from ASME code quarterly testing frequen'cg of valves in RCS high point vent sos be granted bg 871113.
DISTRIBUTION CODE:
A047D COPIES RECEIVED: LTR ENCL SIZE:
TITLE:
OR Submittal:
Inservice Inspection/Testing NOTES: Application for permit reneeal filed.
05000400 RECIPIENT ID CODE/NAME PD2-1 L*
BUCKLEYiB INTERNAL: AEOD/DOA ARM/DAF/LFMB NRR/DEBT/MTB OQC/HDS1 RES/DE/EIB EXTERNAL:
LPDR NSIC COPIES LTTR ENCL 1
0 1
1 1
1 1
0 1
0 1
1 1
1 RECIPIENT ID CODE/NAME PD2-1 PD AEOD/DSP/TPAB NRR/DEST/MEB N
/ILRB REQ FILE 01 NRC PDR COP IES LTTR ENCL 5
5 TOTAL NUMBER OF COPIES REQUIRED:
LTTR 19 ENCL ib
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SSM Carolina Power 8 Light Company OCf 30 ~
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<DOC> 05000y00 PDR SERIAL: NLS-87-230 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-000/LICENSE NO. NPF-63 IN-SERVICE PUMP AND VALVETESTING (IST) PROGRAM Gentlemen:
Carolina Power R Light Company (CPRL) hereby submits a supplement to the SHNPP IST program in accordance with 10CFR50.55a(g)(5) and requests that expedited relief be granted on the enclosed relief request by November 13, 1987.
Carolina Power dc Light Company is requesting relief from the ASME code quarterly testing frequency of valves in the Reactor Coolant System (RCS) High Point Vent System.
These vents are required by NUREG-0737, "Clarification of TMI Action Plan Requirements, Item II.B.l. As required by NUREG 0737, these valves provide a means to vent noncondensible gases from the RCS which may inhibit core cooling during natural circulation. The scenarios for which these valves would be used are beyond the design basis of the plant.
Use of these valves is covered by emergency operating procedures as required by NUREG-0737.
Also, as required by NUREG-0737, the vents must not lead to an unacceptable increase in the probability of a loss-of-coolant accident and must be designed to ensure a low probability of inadvertent or irreversible actuation.
The SHNPP design (refer to attached Figure) consists of six solenoid-actuated, pilot-operated valves.
The valves are normally closed and provide a double RCS barrier.
The valves vent to the containment or the Pressurize Relief Tank (PRT).
The only routine use of the valves occurs during filland vent of the RCS.
These valves were originally the subject of relief request RV-2 in Revision 1 of the IST program submitted on 3anuary 21, 1986.
The staff, in a letter dated 3une 10, 1986, requested additional justification for the relief request.
Because of a perceived schedular impact, CPRL chose not to pursue this relief request over others of greater priority. However, there were and still are safety and operational reasons for not testing these valves at system pressure (i.e., Modes 1-0). Therefore, CPRL is reinitiating this relief request.
Technical Specification 3.0.11 requires that one vent path from the reactor pressure vessel head and one vent path from the pressurizer be operable and closed during operation.
Technical Specification OA.11.2.a requires testing of the vent valves every 18 months.
The In-service Testing program required by Technical Specification 0.0.5 requires testing of these valves quarterly. Testing of the valves with the RCS pressurized 411 Fayettevilte Street o P. O. Box 1551 o Raleigh, N. C. 27602 (t,41
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Document Control Desk PALS-87-230 / Page 2 could result in a limited but uncontrolled blowdown should the associated upstream or downstream valve fail, inadvertently open, or experience excessive leakage during testing.
The result would be a loss of RCS inventory to the pressurizer relief tank or containment atmosphere in excess of Technical Specification 3.0.6.2.d limits, possibly resulting in unit shutdown.
Testing at power; i.e., with the RCS pressurized, has demonstrated that a scenario exists by which the block valves can be forced open during testing of the upstream vent valve(s).
This is due to a combination of valve test sequencing, timing, and the particular characteristics of the valves'luid assisted operation.
This scenario has been addressed by an orientation change of the block valves and changes in the test procedure.
These changes will improve the reliability of these valves by:
- 1) reducing the time necessary to fullyreseat the valve discs and 2) by not challenging the valves before the discs are fully reseated.
Given that these valves are not assumed to operate in design basis accidents and the potential consequences of testing them at full system pressure, testing of these valves at power is contrary to both the goal of maintaining double isolation of the RCS and the NUREG-0737 requirement to ensure a low probability of inadvertent or irreversible actuation of the valves.
For the above reasons, testing these valves in Modes 1-0 is impractical and, therefore, CPRL requests relief in the form of refueling frequency testing of these vent valves.
Carolina Power R Light Company willrequest under a separate letter that the quarterly testing of the block valves be deleted from the Technical Specification 0.0.11.1.
If you have any questions please contact Steven D. Chaplin at (919) 836-6623.
Yours very truly, SDC/mss (5319SDC)
S.. Zim erman Man er Nuclear icensing Section Attachment cc:
Mr. B. C. Buckley Dr. 3. Nelson Grace Mr. G. F. Maxwell
RV-2 Valves:
IRC 900~ 901~ 902~ 903~ 900~ 905
~Cate or:
Class:
Function:
RCS Vent Valves Test Re irement:
Basis for Relief:
Exercise valve for operability, observe proper operation of fail-safe actuator and measure stroke time quarterly.
Valves are RCS High Point Vent Valves, which were installed in response to NUREG 0737, Item II.B.1 and are designed
~onl to vent noncondensible gas produced by a "beyond design basis accident" from the RCS.
These valves are only routinely used during cold shutdown to provide a path for normal RCS venting prior to heatup.
Technical Specification 3.0.11 requires that one vent path from
'he reactor pressure vessel head and one vent path from the pressurizer be operable and closed during operation.
Technical Specifications requires testing of the vent valves every 18 months.
Testing of the valves during power operations could result in a limited but uncontrolled blowdown should the associated upstream or downstream valve fail, inadvertently open, or experience excessive leakage.
The result would be a loss of RCS inventory to the pressurizer relief tank or containment atmosphere in excess of Technical Specification 3.0.6.2.d limits, possibly resulting in unit shutdown.
Alternate Test:
Exercise valve for operability, observe proper operation of fail-safe actuators, and measure stroke time with the RCS depressurized during a refueling.
(5319SDC/mss
)
IAC-002 COIITAnllfIIT ATIIOSPIEAE PORY w IAC-1103
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