ML18067A566

Forwards Addl New Valve Relief Request for Approval,Per 10CFR50.55a(a)(3).Approval of Valve Relief Request,Requested Prior to 980123 to Allow for Planning for 1998 Refueling Outage Sheduled to Commence in May 1998

ML18067A566
Person / Time
Site:	Palisades
Issue date:	06/03/1997
From:	Bordine T CMS ENERGY CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-89-04, GL-89-4, NUDOCS 9706100317
Download: ML18067A566 (7)

Text

A CMS Energy Company TllOllUI* t:. BordlaB Manager Licensing June 3, 1997 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT INSERVICE TESTING PROGRAM -VALVE RELIEF REQUEST 32 On March 5, 1996, Consumers Energy submitted its third 120-month interval inservice testing (IST) program for the Palisades Plant. On August 30, 1996, the NRC responded with their Safety Evaluation Report (SER) of the relief requests contained in that program.

An additional new valve relief request (VRR) is attached for approval in accordance with the requirements of 10 CFR 50.55a(a)(3). This VRR is numbered consecutively within the lnservice Testing Program for valve testing and its number follows the last VRR which was submitted on March 5, 1996, and evaluated on August 30, 1996. This VRR is therefore uniquely identified as VRR No. 32.

Palisades proposes to extend the disassembly and inspection interval for CK-ES3216 and CK-ES3226, such that, both valves will be disassembled and inspected at full core off-loads or when shutdown cooling can be isolated, provided the valves have not been i

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disassembled and inspected in the previous 40 months. * --AJ<-fl I Approval of this VRR is requested prior to January 23, 1998, to allow for planning for the 1998 refueling outage scheduled to commence in May, 1998.

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Palisades Nuclear Plant

• 27780 Blue Star Memorial HighWay

• Covt:il, Ml 49043

• Tel: 616 764 2913

• Fax: 616 764 2490

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SUMMARY

OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.

Thomas C. Bordine Manager, Licensing CC Administrator, Region Ill, USNRC

, *Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment

1,;y ATTACHMENT CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 INSERVICE TESTING PROGRAM VALVE RELIEF REQUEST 32 4 Pages

• RELIEF REQUEST BASIS NUMBER 32 SYSTEM: Engineering Safeguards (Containment Spray/M203-2)

VALVES: CK-ES3216, CK-ES3226 CATEGORY: c CLASS: 2 FUNCTION:

These eight inch check valves perform an active safety function in the open position to admit containment spray flow to the spray headers. These valves open when containment spray is automatically initiated on a Containment High Pressure (CHP) signal.

These valves have no safety function in the closed position. Since the containment spray system will be in operation during an accident condition requiring containment integrity, these valves are not considered to be required for containment integrity. These valves function to prevent backflow to the shutdown cooling system during system testing.

TEST REQUIREMENT:

ASME/ANSI OMa-1988, Part 10 4.3.2.2: Exercising Requirements (a) During Plant operation, each check valve shall be exercised or examined in a manner which verifies obturator travel to the closed, full open, or partially open position required to fulfill its function.

(e) If exercising is not practical during Plant operation or cold shutdowns, it may be limited to full-stroke during refueling outages.

4.3.2.4: Valve Obturator Movement (a) The necessary valve obturator movement shall be demonstrated by exercising the valve and observing that either the obturator travels to the seat on cessation or reversal of flow, or opens to the position required to fulfill its function, as specified in para.1.1, or both.

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• RELIEF REQUEST BASIS NUMBER 32 Observation may be by observing a direct indicator such as a position indicating device, or by other indicator(s) such as changes in system pressure, flow rate, level .temperature, seat leakage testing or other positive means. * *

(b) If manual mechanical exerciser is used to move the obturator, the force or torque required to initiate movement (breakaway) shall be measured and recorded. The breakaway force shall not vary by more than 50% from the established reference value. The reference value used shall be the value obtained when the valve is

• known to be operating properly, and shall be taken under conditions as close as practicable to the conditions under which the valve will be tested, e.g., wet vs. dry equivalent static head, etc.

(c) As an alternative to the testing in (a) or (b) above, disassembly every refueling outage to verify operability of check valves may be used.

Generic Letter No. 89-04 Position 2: The NRG staff position is that valve disassembly and inspection can be used as a positive means of determining that a valve's disk will full-stroke exercise open or of verifying closure capability.

c. Where the licensee determines that it is burdensome to disassemble and inspect all the applicable valves each refueling outage, a sample disassembly and inspection plan for groups of identical valves in similar applications may be employed.

BASIS FOR RELIEF:

Relief is requested in accordance with 10CFR50.55a(a)(3) from disassembling and inspecting a sample (one) valve each refueling outage on the basis that the alternative proposed will provide an acceptable level of quality and safety.

The result of a full-stroke exercise of the containment spray check valves would be the initiation of the containment spray system and spraying down 2

• RELIEF REQUEST BASIS NUMBER32 containment. The original Plant design did not provide a test circuit for these valves. As a result, full stroke testing is not practical during any mode of operation. Therefore, because of this limitation, Palisades has implemented disassembly and inspection, and part stroke testing in accordance with Generic Letter 89-04. This program requires one valve of the group composed of CK-ES3216 and CK-ES3226 to be disassembled and inspected each refueling outage, and quarterly part stroke testing when the plant is in cold shutdown.

During periods where shutdown cooling is required, the disassembly would require a single valve isolation from the Containment Spray System using a valve with air operator closure. Loss of control air to this single valve could result in a loss of shutdown cooling or reduced shutdown cooling effectiveness.

Leakage past the valve could also present difficulties in completing valve inspections. Disassembly of the containment spray check valves also results in increased dose to plant staff on the order of 200mR.

Valve CK-ES3216 was disassembled and inspected during the 1994 refueling outage in accordance with work order 24416316. This was the first disassembly and inspection performed since initial plant installation and testing. Inspection indicated the valve was in good condition with little or no degradation after 23 years of service.

Valve CK-ES3226 was disassembled and inspected during the 1996 refueling outage in accordance with work order 24613344. This was the first disassembly and inspection performed since initial plant installation and testing. Inspection indicated the valve was in good condition with *little or no degradation after 25 years of service.

A review of industry experience for this type of valve does not indicate any adverse performance experience associated with valves in mild service similar to

.the containment spray header check valves. The containment spray system is composed of stainless steel piping components rated at 500 psig and 350 °F, and transports clean borated water. The spray header check valves do not see service conditions at any time other than system surveillance testing. No degradation mechanisms associated with system service or testing have been identified.

A search of Palisades specific experience indicates no corrective actions or work orders associated with these valves.

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• RELIEF REQUEST BASIS NUMBER32 ALTERNATIVE TESTING:

Valves CK-ES3216 and CK-ES3226 will be part-stroke exercised quarterly each cold shutdown per Q0-10.

Palisades proposes to extend the disassembly and inspection interval for CK-ES3216 and CK-ES3226, such that, both valves will be disassembled and inspected at full core off-loads or when shutdown cooling can be isolated, provided the valves have not been disassembled and inspected in the previous 40 months.

At each disassembly, the valves will be manually exercised to verify full-stroke capability. Also, the disassembled valve will be inspected to ensure the internals are structurally sound (no loose, damaged, or corroded parts).

ACCEPTANCE CRITERIA:

At each disassembly, the valves will be manually exercised to verify full-stroke capability. Also, the disassembled valve will be inspected to ensure the internals are structurally sound (no loose, damaged, or corroded parts).

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