ML19317G459

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Forwards Addl Info Supporting Request for Relief from ASME Section XI Requirements for Inservice Insp & Testing Program
ML19317G459
Person / Time
Site: Crystal River 
Issue date: 03/02/1977
From: Rodgers J
FLORIDA POWER CORP.
To: Stolz J
Office of Nuclear Reactor Regulation
References
2210, TAC-04548, TAC-4548, NUDOCS 8003160067
Download: ML19317G459 (30)


Text

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FROM: Florida Power Corp.

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Mr. J Stolz 3-2-77 J.T. Rodgers St. Petersburg, Fla. 33733 DATE RECUVE D f

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(4P) releif from ASME Section XI requirements dealing with pump inservice inspection waiver request.....

Encl. 2-4 entitled valve Inservice Inspection Waiver Request.....

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SUBJECT:

Florida Power Corporation Crystal River Unit #3 Docket No. 50-302

Dear Mr. Stolz:

On December 15, 1976 Florida Power Corporation filed with the Commission a request for relief from the requirements of the ASME Boiler and Pressure Vessel Code,Section XI. Our submittal contained a detailed Inservice Inspection and Testing Program for Crystal River Unit 3.

Based on your review of our December 15th submittal, you granted Florida l

Power relief from the ASME Code requirements pursuant to Section 4.0.5a of the CR#3 Technical Specifications, for the period of time from issu-ance of the facility operating license on December 3,1976, to the start of facility comercial operation. You further requested FPC in Supple-ment No. 3 to the staff's SER dated December 30, 1976 to provide by March 3,1977, for your review, the specific exceptions from the ASME Code requirements determined to be impractical, and the information to support these exceptions. Mr. Boyd's letter of February 1, 1977, formally transmitted to us the specific information your staff needs to make an evaluation of our request for relief pursuant to 10 CFR 50.55a(g) (6) (1).

In response to your request we hereby transmit 43 copies of additional information in support of our request for relief from ASME Section XI requirements that we have determined to be impractical, in accordance with the Comission's guidance letter of February 1,1977. Our program is based on ASME Code Section XI,1974 Edition through summer 1975 Addenda for the period of 20 months following comercial operation

-M-Q-General Office 3201 Tniny-founn s:reet soutn. P O Box 14o42. st Petersburg. Fiorica 33733 813 - 866-5151

Page 2 for the Pump and Valve Testing Program and for the period of 40 months following commercial operation for the Inservice Inspection Dppgram, Enclosures 1 through 4 identify each pump and valve to which the above ASME Code applies and which code requirements of Section XI are con-sidered to be impractical. Also included in our response is an imple-mentation schedule as requested in the Commission's February 1, 1977, letter.

Although the number of specific components for which we seek relief from the ASME Code is small we will require additional time to implement the new code requirements that can be met but are not presently included in our Pump and Valve Testing Program. We hereby request that we be granted until September 3,1977, for complete implementation of the pump testing program based on the new ASME Code and until March 3,1978, for complete implementation of the valve testing program. This additional time for implementation is required in order that our present surveillance procedures can be revised to include the new code requirements from which relief is not being sought. We feel that this additional time will enable an orderly implementation of these new code requirements without compromising in any way the safety of the plant.

Your February 1,1977, letter also requested additional information concerning our Inservice Inspection Program. The baseline classifi-cation of Class 1 and 2 components at CR#3 were Non-Destructive Examined (NDE) per ASME Section XI 1971 Edition through winter 1972 Addenda.

We are presently working with B&W upgrading this baseline information for Class 1 and 2 components into an Inservice Inspection Program based on ASME Section XI 1974 Edition through Summer 1975 Addenda and identifying those areas where code requirements cannot be met. A detailed comparison is also being made between existing plant repair, welding and inspection

- procedures and the requirements of ASME Section XI to identify areas where relief is required. Waiver requests for those code requirements determined to be impractical will be submitted to the Commission on or before April 15, 1977.

Class 3 components and those excludeo from Class 1 and 2 NDE requirements are presently being reviewed to deteraine where hydrostatic and visual inspections per ASME Section XI are impractical.

Waivers for components where these two code requirements are impractical will be submitted to the Commission on or before April 15, 1977.

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Page 3 Development of the Inservice Inspection Program for Crystal River Unit 3 based on ASME Section XI, 1974 Edition through Summer 1975 Addenda, will not be finished until October, 1977. This is well in advance of the inservice inspection required for CR#3 which is currently scheduled during the first refueling outage in the fall of 1978.

It is hereby requested that Florida Power be granted waivers from those Code requirements identified in Enclosures 1 thru 4 of this letter in-cluding the implementation dates. It is also requested that you grant acceptance of the April 15, 1977 submittal date for the Inservice Inspection Program waiver requests and the October 1977 Inservice Inspection Program development date.

Very truly yours, J.T. Rodgers Asst. Vice President ECS/hw 3/19 a

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IN WITNESS WHEREOF, the applicant has caused its name to be hereunto signed by J.T. Rodgers, Assistant Vice President, and its corporate seal to be hereunto affixed by Betty M. Clayton, Assistant. Secretary, thereunto duly authorized the 2nd day of March,1977.

FLORIDA POWER CORPORATION By A

J.T./Rodg4rs 47 Assistant Vice President ATTEST Betty M. Clayton Assistant Secretary (CORPORATESEAL)

Sworn to and subscribed before me this 2nd day of March, 1977.

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Notary Public My Commission Expires:

Notary Public State of Florida at Large My Commission Expires July 9, 1978 w

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{QG:$.Tj. Je*i ENCLOSURE 1 Pump Inservice Inspection Waiver Request The attached pages identify in tabular form the pumps at CR#3 to which Section XI of the ASME Code applies. The waiver requests for these e

pumps provides the following information as requested in the Appendices of your February 1, 1977 guidance letter:

"(1) Name and Tag No. in FSAR.

(2) Function.

(3) ASME code class.

(4) Test frequency.

(5) Code requirement that has been determined impractical.

(6) Justification for waiver.

(7) Alternate inservice testing program.

(8), Implementation schedule.

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Rev. 1 ENCLOSURE 1 2/28/77 YUMP INSERVICE INSPECTION WAIVER REQUEST ASME Section XI - 1974 thru Summer 1975 Addenda Name: Building Spray Pumps Tag No.'s: BSP-1A & IB ASME Class:

2 Frequency: Monthly - (M)

Yearly - (Y)

FUNCTION:

This is an ES pump and has no normal operating function.

In the event of a major accident it would reduce leakage of radioactivity from the reactor building to the surroundings by injecting spray water into the reactor building to reduce its temperature and pressure.

Impractical Code Requirement Reason for Waiver Alcernate Test Plan 1.

Pi, Inlet Pressure (M)

Instrumentation not installed Each containment spray system shall be demonstrated to measure Pi &/1 P.

OPERABLE:

2.

21 P, Differential At least once per 31 days on a STAGGERED TEST BASIS by:

Pressure (M) 1.

Starting each spray pump from the control room.

2.

Verifying, that on recirculation flow, each spray pump develops a discharge pressure of

> 190 psig at a flow of J2_ 1500gpm.

3.

Verifying that each spray pump operates for at least 15 minutes.

4.

Verifying that each spray pump is aligned to receive electrical power from separate OPERABLE emergency busses.

3.

V, Vibration (M)

No. permanent instrumentation The BSP's will be checked every six months for is available to monitor vibra-vibration and oil level.

4.

Proper Lubricant tion. This will have to be Level (M) done locally using portable test equipment in an aree of potentially high radiation, per the FSAR.

(1 100 mr/hr)

Implementation Schedule:

The operability verification of the BS pumps is presently implemented. Monitoring the mechanical and hydraulic parameters as required in the IWP Section of ASHE Section XI with l

the exceptions noted ir. the above waiver will be implemented before September 3, 1977.

This additional time for implementation is required as the surveillance program procedures must be revised to include those new code requirements which can be complied with but are not presently included in the surveillance program for CRf3.

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ENCLOSURE 1 (con't) gay, 1 -

DUMP INSERVICE INSPECTION WAIVER REQUEST 2/28/77 ASME Section XI - 1974 thru Summer 1975 Addenda N;mes Boric Acid Pumps Tag No. 's: CAP 1 & 2 ASME Classi 3

Frequency: Monthly - (M)

Yearly - (Y)

FUNCTION:

The boric acid pumps furnish boric acid for the reactor coolant system, core flooding tanks, spent fuel storage pool and the borated water. storage tank to control reactivity.

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I prcctical Code Requirement Reason for Waiver Alternate Test Plan l.

Pi, Inlet Pressure (M)

Instrumentation not available The Boric Acid Pumps shall be demonstrated OPERABLE to measure P,1, Q,Jb6P, V, at least once per 7 days by:

2.

JOLP, Differential and Th.

The pumps are Pressure (M) canned rotor pumps, encased a.

Starting (unless already operating) the pump with insulation, from the control room.

3.

Q. Flow Rate (M) b.

Verifying, that on recirculation flow, the pump' develops a discharge pressure of ]> 60 psig.

4, V, Vibration (M) c.

Verifying pump operation for at Icast 15 minutes, and 5.

Tb, Bearing d.

Verifying that the pump is aligned to receive Temperature (Y) electrical power from an OPERABLE emergency bus.

The level of the boric acid tank will be recorded 6.

Proper Lubricant Lubrication by the pumping Level (H) medium.

In lieu of inlet pressure.

Irplementatiin Schedule: The operability verification of the boric acid pumps is presently implemented.

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ENCLOSURE 1 (con't)

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PUMP INSERVICE INSPECTION WAIVER REQUEST ASME Section XI - 1974 thru Summer 1975 Addenda Name:

Chilled Water Pumps-

.sj No.'s: CIIP 1A & IB ASME Class:

3 Frequency: Monthly --(M)

Yearly - (Y)

FUNCTION:

These pumps furnish chtlled water to the ventilation system, cooling the control complex, penetration cooling and the switchgear room.-

Isepractical Code Requirement.

Reason for Waiver Alternate Test Plan 1.

Q, Flow Rate (M) instrumentation Annually verify there is sufficient flow to cool available the control complex.

Implementation Schedule: Mechanical and hydraulic characteristics, and operability verification procedures and acceptance limits will have to be developed. Testing to begin not later than September 3, 1977.

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Rev. 1 ENCLOSURE 1 (con't) 2/28/77 PUMP IN.cERVICE INSPECTION WAIVER REQUEST -

ASMR ection XI - 1974 thru Summer 1975 Addenda TalgNo.'s:

Name: Decay Heat Closed Cycle DCP 3A & 3B ASME Class:

3 Frequency: Monthly - (H)

Cooling Pumps l Yearly. - (Y)

FUNCTION:

The DilCCCiPumps:

1.

Remove the heat of decay released by the reactor after shutdown, 2.

To supplement other methods of cooling following a gross release of primary coolaat or main! steam inside the containment, and 3.

Provide a barrier between a potentially radioactive coolant and the sea.

Impractical Code Requirement Reason for Waiver Alternate Test Plan 1.

Q, Flow Rate (M)

Instrumentat, ion not Each decay heat closed cycle cooling water loop installed to measure shall be demonstrated OPERABLE:

flow.

A.

At least once per 31 days on a STAGGERED TEST BASIS by:

1.

Starting each pump (unless aircady operating from the control room.

2.

Verifying that each pu,mp develops at least 93% of the shutoff discharge pressure as determined from the manufacturer's Pump Performance Curve.

3.

Verifying that each pump operates for at least 15 minutes.

4.

Verifying that each loop is aligned to receive electrical power from. separate.

OPERABLE emergency busses.

Implementation Schedule:

The operability verification of tl e DC pumps is presently implemented. Monitoring the mechanical and hydraulic parameters as required in the IWP Section of ASME Section XI with the exceptions noted in the above waiver will be implemented before September 3, 1977.

This additional tirru for implementation is required as the surveillance program procedures must be revised to include those new code requirements which can be complied with but are not presently included in the surveillance program for CRf 3.

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i ENCLOSURE 1 (con't)

Rev. 1

' PUMP INSERVICE INSPECTION WAIVER REQUEST 2/28/77 ASME Section XI - 1974 thru Summer 1975 Addenda Nrme: Decay Heat Pumps Tag No.'s: DHP 1A & IB ASME Class:

2 Frequency: Monthly - (H)

Yearly - (Y)

FUNCTION:

The decay heat pumpsare normally used to remove decay heat from the reactor core during the latter stages of cool down and in ES function it provides borated water through two separate unconnected paths.

Irpractical Code Requirement Reason for Waiver Alternate Test Plan 1.

P1, Inlet Pressure (M)

Instrumentation not Verify operability of each Decay Heat Pump:

installed to measure Pi and /1 P.'

Starts (unless already operatir.g) from the a.

control room.

2 2h P, Differential b.

Develops a discharge pressure of > 200 psig Pressure (M) on recirculation flow.

c.

Operates for at least 15 minutes.

3.

V, Vibration (H)

No permanent instrumentaticn,

The DHP's will be checked every 6 months for installed to monitor these

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vibration and oil level. The bearing temperatures 4

Proper lubricate Parameters remotely. To will be checked and recorded yearly.

level (H) measure locally using portable test equipment or observations requires a person to enter an area potent.ially high radiation,

'(>_ 100 mr/hr per the VSAR).

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Implementation Schedule:

The operability verification of the DH pumps is prasently implemented. Monitor'ing the mechanical and hydraulic parameters as required in the IWP Section of ASME Section XI with the exceptions noted in the above waiver will be implemented before September 3, 1977.

This additional time for implementation is required as the surveillance program procedures must be revised to include those new code requirements which can be complied with but are not presently included in the surveillance program for CRf 3.

ENCLOSURE 1 (con' t)

Rev. 1 2/28/77

' PUMP INSERVICE INSPECTION WAIVER REQUEST ASME Section XI - 1974 thru Summer 1975 Addenda Name:

Emergency Feedwater Pump Tag No 's:

EFP-1 & 2 ASME Class:

2 Frequency: Monthly - (M)

Yearly - (Y)

FUNCTION:

The EFP provides feedwater to the steam generator to remove the decay heat of the nuclear fuel until suitable conditions are attained to start the decay heat removal system.

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Irpractical Code Requirement Reason for Waiver Alternate Test Plan 1.

Q, Flow rate (M)

No instrumentation Once every 31 days EFP-16 2 shall be verified available tq measure operable by:

Q.

1.

Starting each pump from the control room.

2.

Verify.ing that:

a.

The motor driven pump develops a discharge pressure of > 1100 psig on recirculation

flow, b.

The pump operates for at least 15 minutes.

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Inplementation Schedule: The operability verification of the EFP-1 & EFP-2 pumps is presently implemented.

Manitoring the mechanical and hydraulic parameters as required in the IWP Section of ASME Section XI with the exceptions noted in the above waiver will be implemented before September 3, 1977. This additional time for implementation is required as the surveillance program procedures must be revised to include those new code requirements which can be complied with but are not presently included in the surveillance program for CRf3.

ENCLOSURE 1 (con't)

Page 1 of 2 Rev. 1

' PUMP INSERVICE INSPECTION WAIVER REQUEST 2/28/77' ASME Section XI - 1974 thru Summer 1975 Addenda Name: Make-Up Pumps Tag No. 's: MUP 1A,1B ASME Class: 1 Frequency: Monthly,- (M)

& IC Yearly - (Y)

FUNCTION:

1.

To control the reactor coolant system inventory during all phases of normal reactor operation.

2.

Maintain chemical control.

3.

Provide injection water for the seals on the Reactor Coola..t Pumps, and 4.

In case of a LOCA the system provides llP injection water between normal operational pressure and the pressure which decay heat removal pumps take service.

Irpractical Code Requirement Reason for Waiver Alternate Test Plan 1.

Pi, inlet pressure (M)

Instrumentation not available Make-up tank level and pressure will be recorded to read inlet pressure at during operability verification of each HUP in pump' suction.

lieu of inlet pressure directly at pump.

4 2.

23sP, Differential Instrumentation not available.

At least two makeup pumps shall be' demonstrated Pressure (H)

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OPERABLE at least once per 31 days on a STAGGERED TEST BASIS by:

3.

Q, Flow Rate (M)

Instrumentation not available to measure Q while in recir-a.

Starting (unless already operating) each pump culation mode.

from the control room.

l b.

Verifying, that on recirculation flow, each pump develops a discharge pressure of )

250r psig.

c.

Verifying that each pump operates for at least 15 minutes, and d.

Verifying that each pump is aligned to receive elect'rical power from separate OPERABLE emergency busses.

4.

Proper lubricant level No instrumentation available Low lubrication level for the MUP's, is monitored orpressufe(M) tomfasurethisparameter by annunciator alarms in the Control Room.

j remotely. To measure locally requires a person to enter an area of potentially high radiation

(>

100 mr/hr per the FSAR)

T Page 2 of 2 Rev. 1 ENCLOSURE 1 (con't) 2/28/77-

  • PUMP INSERVICE INSPECTION WAIVER REQUEST ASME Section XI - 1974 thru Summer 1975 Addenda Nime: Make-Up Pumps Tag No. 's: MUP 1A,1B ASME Class: 2 Frequency: Monthly - (H)

& IC Yearly - (Y)

FUNCTION:

See Page l'of 2 Irpractical Code Requirement Reason for Waiver Alternate Test Plan 5.

V, Vibration (M)

Permanent instrumentation Bearing temperatures are monitored by the plant not available to measure computer. Any degradation by the bearings would vibration. To measure be reflective of high bearing temperature and locally requires a person be alarmed by the computer.

to enter an area of potent-ially high radiation Vibration check will be recorded with the frequency (2_100 mr/hr per FSAR).

of once every 6 months.

Implementation Schedule:

The operability verification of the HU pumps is presently implemented. Monitoring the mechanical and hydraulic parameters as required in the IWP Section of ASME Section XI with the exceptions noted in the above waiver will be implemented before September 3, 1977.

This additional time for implementation is required as the surveillance program procedures must be revised to include those new code requirements which can be complied with but are not presently included in the surveillance program for CRf3.

R cy.- 1 ENCLOSURE 1 (con' t) 2/28/77 PUMP INSERVICE INSPECTION WAIVER REQUEST' ASME Section XI - 1974 thru Summer 1975 Addenda m

N me: Nucicar Services Seawater Pumps Tag No. 's: RRP 2A & 2B ASME Class: 3 Frequency: Monthly - (M)

Yearly - (Y)

FUNCTION:

These pumps furnish sea water which provides a heat sink for nucicar oriented equipment.

I Impractical Code Requirement Reason for Waiver Alternate Test Plan 1.

Pi, Inlet Pressure Instrumentation not available The nuclear service sea water aystems shall be (M) to measure Pi,21 P, and Q.

demonstrated OPERABLE:

2.

[\\P, Discharge At least once per 31 days on a STAGGERED TEST Pressure (M)

BASIS by:

3.

'Q. Flow Rate (M) 1.

Starting each pump (unless already operating) from the control room.

2.

Verifying that each pump develops at least 93%

of the shutoff head as determined from the manufacturer's Pump Performance Curve.

3.

Verifying that each pump operates for at least 15 minutes.

4.

Verifying that each pump is aligned to receive electrical power from separate OPERABLE emer-gency busses.

Izplementation Schedule:

The operability verification of the RW pumps 2A & 2B is presently implemented.

Monitoring the mechanical and hydraulic parameters as required in the IWP Section of ASME Section XI with the exceptions noted in the above waiver will be implemented before September 3, 1977.

This additional time for implementation is required as the surveillance program procedures must be revised to include those new code requirements which can be complied with but are not presently included in the surveillance program for CRf3.

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ENCLOSURE 1 (con't) 77 PUMP INSERVICE INSPECTION WAIVER REQUEST ASME Section XI - 1974 thru Summer 1975 Addenda N:me: Decay Heat Seawater System Tag No.'s: RWP 3A & 3B ASME Class: 3 Frequency: Monthly - (H)

Yearly - (Y)

FUNCTION:

The DilRW pumps furnish seawater which provides a heat sink for nuclear oriented equipment.

Impractical Code Requirement Reason for Waiver Alternate Test Plan 1.

Pi, Pressure Inlet (M)

. Instrumentation not available Each decay heat sea water loop shall be demonstrat to measure Pi,z$,P, and Q.

OPERABLE:

2.

/\\ P, Differential Pressure (M)

At least once per 31 days on a STAGGERED TEST BASIS by:

.3.

Q, Flow (M) 1.

Starting each pump (unless already operating) from the control room.

2.

Verifying that each pump develops at least 93%

of the shutoff head as determined form the.

manufacturer's Pump Performance Curve.

3.

Verifying that each pump operates. for at least -

15 ainutes.

4.

Verifying that each loop is aligned to receive electrical power from separate OPERABLE emergency busses.

Irplementation Schedule:

The operability verification of the RW pumps 3A & 3B is presently implemented. Monitoring the mechanical and hydraulic parameters as requi, red in the IWP Section of ASME Section XI with the exceptions noted in the above waiver will be implemented before September 3, 1977.

This additional time for, implementation is required as the surveillance program procedures must be revised to include those new code requirements which can be complied with but are not presently included in the surveillance program for CRf3.

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I Rev. 1 ENCLOSURE 1 (con't) 2/28/77 PUMP INSERVICE INSPECTION llAIVER REQUEST ASME Section XI - 1974 thru Summer 1975 Addenda N me:- Spent Fuel Pumps Tag No.'s: SFP 1A & IB ASME Class: 3 Frequency: Monthly - (M)-

Yearly - (Y)-

FUNCTION:

The spent fuel coolant pumps remove decay heat from the spent fuel storage pool water to ensure adequate cooling of irradiated stored assemblies.

Impractien1 Code Requirement Reason for Waiver Alternate Test Plan 1.

P1, Inlet Pressure (M)

Instrument not available for Prior to the.lst refueling, the SF pumps cannot Pi andaOLP.

be run in normal mod, due to no water being in the spent fuel pools. Therefore prior to the 2.

/\\ P, Differential 1st refueling we propose to verify operabilJty Pressure (M) of the spent fuel pumps by performing the followir.g:

1.

Visually inspect for:

a.

Oil nnd water leaks b.

Foreign object damage c.

Deterioration and rust 2.

Check and adjust packing as necessary.

3.

Record Vibration Amplitude.

4.

Record Discharge' pressure at the pump.

5.

Record flow rate.

6.

Bearina temperatures will be recorded yearly.

Iwplementation Schedule: One month prior to initial refueling the above checks will be on a monthly basis.

-s ENCLOSURE 1 (con't)

Rev. ]

' PUNP INSERVICE INSPECTION UAIVER REQUEST 2/28h7.

ASME Section XI - 1974 thru Summer 1975 Addenda Name: Nuclear Services Closed Cycle Tag No. 's: SWP 1A & IB ASME Class: 3 Frequency: Monthly - (H)

Cooling Water Pumps Yearly (Y)

FUNCTION:

The NSCCC Pumps provides:

1.

An essential heat sink for nucicar oriented equipment, 2.

A redundent function to the RB spray for removing heat inside the RB following I

a major accident and, 3.

Preventative for release of radioactivity to the sea by means of an intermediate barrier between the primary coolant and the sea.

Irpractical' Code Requirement Reason for Waiver Alternate Test Plan 1.

Q, Flow Rate (H)

Instrumentation not installed.

The nuclear services closed cycle cooling system shall be demonstrated OPERABLE:

At least once per 31 days by:

1.

Starting each pump (unless already operating) from the control room.

2.

Verifying that each pump develops at 1 cast 93%

of the shutoff discharge pressure from the manufacturer's Pump Performance Curve.

3.

Verifying that each pump operates for at least 15 minutes.

a 4.

Verifying that each pump is aligned to receive electrical power from separate OPERABLE emergency busses.

Implementation Schedule:

The operability verification of the SW pumps is presently imp'lemented. Monitoring the mechanical and hydraulic parameters as required in the IWP Section of ASME Section XI with the exceptions noted in the above waiver will be implemented before September 3, 1977.

This additional time for implementation is required as the surveillance program procedures must he revised to include those new code requirements which can be complied with but are not presently included in the surveillance program for CRf 3.

ENCLOSURE 2 --4 Valve Inservice Inspection Waiver Request The attached pages identify in tabular. form the valves at CR#3 to which Section XI of the ASME Code applies.

The information provided is in the form requested in the Appendices of your February 1, 1977 letter.

Specifically the Enclosures include:

'(1) - listing of valves for which the present inservice testing program is in compliance with the new ASME Code requirements.

Included in the listing are the

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ASME Valve Categories, type of test, and test frequency.

(2) - listing of valves for which the inservice testing program will be in compliance with Section XI of the ASME Code by March 3,1978, once present surveillance procedures are revised to include the latest code requirements.

However, for most of the valves listed in Enclosure 3, the present surveillance program confirms the operability of the valve but the procedures do not meet Section XI requirements and therefore must be revised. Included in the listing are the ASME valve categories, type of test, and test frequency.

(3) - valve inservice inspection waiver requests from ASME Section XI - 1974 Edition thru Summer 1975 Addenda.

Included in the waiver requests are:

a.

Name and number of valve.

b.

ASME code class.

c.

Function of valve, d.

ASME valve category.

e.

Impractical code requirement.

f.

Justification for waiver.

g.

Alternate test plan.

h.

Implementation schedule.

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ENCLOSURE 2 Listing of Valves in Compliance with ASME Code at Present Ti=e Category A and B Valves _ - Full Stroked During Cold Shutdown

  • Core' Flood - CFV-1, 3 Category C Valves - Check Valves, Full Scroked During Cold Shutdown
  • Core Flood - CFV-1, 3 Category C. Valves _ - Safety Valves, Tested Every 5 Years *
  • Main Steam - MSV-33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45 46, 47, 48 Reactor Coolant - RCV-8, 9 Category E Valves **
  • Building Spray - BSV-38, 85, 90, 91, 96 Steam Cenerator Chemical Cleaning - CGV-35, 36, 37, 38 Decay Heat Closed Cycle Cooling - DCV-27, 28, 29, 30, 33, 34, 35, 36, 95, 96, 115, 117, 118, 119, 120 i

Decay Heat Removal - DHV-99, 100, 101, 102, 103, 104 l

Emergency Feedwater - EFV-23, 24, 31 Feedwater - FW-85, 86 46, 401, 404, 409, 410

, Main Steam - MSV-114, 117, 128,-132, 134, 1 Make-up - HUV-147, 264, 266 i

Nitrogen - NGV-81

Category A/E Valves - Leak Tested During Refueling Hydrogen Purge - LRV-35, 36, 38, 44, 45, 47, 49, 50, 51, 52 Spent Fuel Cooling - SFV-18, 19 Instrument Air - IAV-28, 29

. Nitrogen - NGV-62, 82 Station Air - SAV-24 Rad. Waste System - WSV-1, 2

  • Normally closed check valves that cannot be operated during normal plant operation (As per IWV-3520, paragraph B).
    • The safety valves will be tested at least onca every 5 years in accordance with ASME PTC 25.2-1966.
      • The code requires that this category of valves be identified-but does not require testing of these valves.

However, our present program vill require that the positions of these valves be verified once every 3 months during normal operations.

9

t ENCLOSURE 3 Listing of Valves that will be in Compliance with Section XI of the ASME Code by March 3, 1978, once present Surveillance Procedures are Revised to Include Latest Code Requirements Category A and B Valves - Full Stroked Every 3 Months Auxiliary Steam - ASV-5

-Reactor Building Spray - BSV-1, 3, 4, 8 Liquid Sampling - CAV-1, 2, 3, 4, 5, 6, 7,126

. Core Flood - CFV-11, 12, 15, 16, 25, 26, 27, 28, 29, 42 Chilled Water - CHV-56, 57, 38, 59, 60, 61, 62, 63, 64, 65, 68, 69 Decay Heat Closed Cycle Cooling - DCV-17, 18, 177, 178 Decay Heat Removal - DEV-5, 6, 11, 12, 33, 34, 35, 36, 41, 91, 110, 111 Emergency Feedwater -

EFV-3, 4, 5, 6, 7, 8, 11, 14, 32, 33, 34, 35 Feedsater - FWV-161, 162 Main Steam - MSV-55, 56, 186, 187 Make-up - MUV-1, 2, 6, 7, 10, 11, 16, 17, 23, 24, 25, 26, 27, 40, 41, 49, 53, 58, 73, 153, 253, 257, 258, 259, 260, 261, 265, 267 Nuclear Service and Decay Heat Sea Water - RWV-34, 35, 36, 37, 38 Spent Puel Cooling - SFV-26, 27, 43, 53

^

Nuclear Service Closed Cycle Cooling - SWV-8, 9,10, 35, 37, 39, 41, 43, 45, 47, 48, 49, 50, 353, 356, 412, 413 Waste Disposal - WDV-3, 4, 60, 61, 62, 94, 405, 406 Air Handling - AHV-1A, 1B, 1C, 1D Industrial Cooling Water - CIV-34, 35, 40, 41 Demineralized Water - DWV-160 Rad. Waste System - WSV-3, 4, 5, 6 m.

V

0 Category A and B Valves - Full Stroked During Cold Shutdown Reactor Building Spray - BSV-36, 37 Core Flood - CFV-5, 6, 17, 18, 19, 20 Decay Heat Removal - DHV-1, 2, 3, 4, 42, 43, 93 Emergency Feedwater - EFV-1, 2,15,16,17,18 Feedsater - FWV-33, 34, 35, 36, 41, 42, 43, 44,157,158 Main Steam - 25, 26, 130, 148, 411, 412, 413, 414 Make-up - MUV-18, 13, 20, 21, 22, 36, 37, 42, 43, 60, 64, 65, 72, 160, 161, 162, 163, 164 Nuclear Service Closed

. Cycle Cooling - SWV-12, 79, 80, 81, 82, 83, 84, 85, 86, 109, 110, 151, 152, 355 Demineralized Water - DWV-162 Category A and B Valves.- Full Stroked and Leak Tested During Refueling Liquid Sampling - CAV-1, 2, 3, 126 Core Flood - CFV-11, 12, 15, 16, 17, 18, 19, 20, 25, 26, 27, 28, 29, 42 Make-up - MUV-18, 40, 41, 49, 53, 162, 253, 257, 258, 259, 260, 261 Waste Disposal - WDV-3, 4, 60, 61, 62, 94, 405, 406 Air Handling - AHV-1A, 1B, 1C, ID Industrial Cooling Water - CIV-34, 35, 40, 41 Demineralized Water-- DWV-160r-162 Rad. Waste Disposal - WSV-3, 4, 5, 6 Category C Valves - Check Valves, Full Stroked Every 3 Months Reactor Building Spray - BSV-1, 8 Chilled Water - CEV-64, 65 Decay Heat Removal - DHV-33,--36 --

Emergency Feedwater - EFV-5, 6, 7, 8, 34, 35 Main Steam - MSV-55, 56, 186, 187 i

Make-up - MUV-1, 2, 6, 7, 10, 11, 153, 265, 267 Nuclear Service and Decay Heat Sea Water - RWV-34, 35, 36, 37, 38 Spent Fr el Cooling - SFV-26, 27 Nuclear Service Closed Cycle Cooling - SWV-8, 9,10, 356, 412, 413 Category C Valves - Check Valves, Full Stroked During Cold Shutdown Core Flood - CFV-17, 18, 19, 20 Decay Heat Removal - DHV-1, 2, 93 Emergency Feedwater - EFV-15,16,17,18

-Feedwater - FWV-41, 42, 43, 44, 157, 158 Main Steam - MSV-25, 26 Makeup - MUV-19, 20, 21, 22, 36, 37, 42, 43, 60, 65, 72,160,161,162,163,164 Demineralized Water - DWV-162 Category C Valves - Safety Valves, Tested Every 5 Years

  • Core -Flood - CFV-23, 24 Chilled Water - CHV-66 Decay Heat Closed Cycle Cooling - DCV-55, 56 Reactor Coolant - RCV-10 Nuclear Services Closed Cycle Cooling - SWV-199, 278 Reactor Building Spray - BSV-42, 43
  • The safety valves will be tested at least once every 5 years in accordance with ASME PTC 25.2-1966.

ENCLOSURE 4 VALVE INSERVICE INSPECTION WAIVER REQUESTS ASME SECTION XI - 1974 thru Summer 1975 Addenda N:me:

Reactor Building Spray System Valve No.'s:

BSV-26, 27 ASME C1. ass: 2 ASME Valve Category: B/C FUNCTION: Containment isolatiori valves (normally closed). Must open following an emergency condition requiring Reactor Building Spray System actuation.

Irpractical Code Requirement Reason for Waiver Alternate Test Plan Valves required to be stroked Verifying operability once every 5 years valve operability every 3 months or during by stroking valxes will be verified by performing an air rafueling.

would require actuation or smoke flow test, per Technical of the R. B. Spray System.

Specification 4.6.2.1.d Implementation Schedule: The Alternate Test Plan is presently imple.mented.

-)

l.

ENCLOSURE 4 (con't)

VALVE INSERVICE INSPECTION WAIVER REQUESTS ASME Section XI - 1974 thru Summer 1975 Addenda Name:

Reactor Building Spray System Valve No.'s: BSV-152, 153 ASME Class: 2 ASME Valve Category: B/C FUNCTION: 'Normally closed check valves which must open following an emergency condition requiring Reactor Building Spray System actuation, to allow N 0li to enter the Spray System.

A Irpractical Code Requirement Reason for Waiver Alternate Test Plan Velves required to be stroked Verifying operability of At least once every 5 years every 3 months or during these valves by stroking during refueling, each valve refueling.

is not practical as no means will be disassembled and in-of positive indication exist spected on e staggered basis.

to verify check valve stroking.

l Icplementation Schedule:

The Alternate Test Plan will be implemented before March 3, 1978, as present surveillance program procedures must be revised.

i t

I

a ENCLOSURE 4 (con't)

VALVE INSERVICE INSPECTION WAIVER REQUESTS ASME Section XI - 1974 thru Summer 1975 Addenda Name: Feedwater System Valve No.'s: FWV-39, 40 ASME Class: 3 ASME Valve Category: B FUNCTION:

Control valves. Feedwater regulating valves used during "startups" for flows of 0 to 15 percent power.

During emergency conditions, FWV-39 and 40 are used to control emergency feedwater flow to the Steam Generators.

1rpractical Code Requirement Reason for Waiver Alternate Test Plan Velves required ts he stroked As these valves are used Once a year the valves will be every 3 months.

only for control purposes calibrated for flow settings.

and not feedwater isolation, verification of full stroking is not necessary.

Implementation Schedule:

The Alternate Test Plan is presently implemented.

ENCLOSURE 4 (con' t)

VALVE INSERVICE INSPECTION WAIVER REQUESTS ASME Section XI - 1974 thru Summer 1975 Addenda Name:

Feedwater System Valve No.'s: FWV-45, 46 ASNE Class: 2 ASME Valve Category: B/C FUNCTION:

Containment isolation valves (normally open). Restricts backflow from the Steam Generators to the Main Feedwater System during emergency conditions when the Emergen,cy Feedwater System is in operation.

Impractical Code Requirement Reason for Waiver Alternate Test Plan Valves required to be stroked No practical test method None proposed.

every 3 months or during to verify valve closure.

rsfueling.

O 4

ENCLOSURE 4 (con't)

VALVE INSERVICE INSPECTION WAIVER REQUESTS ASME Section XI - 1974 thtu Summer 1975 Addenda ASME Class ASME Valve Category Name: Decay lleat System Valve No.'s:

DilV-1 1

A/C DiiV-2 1

A/C DHV-4 1

A DlIV-41 2

A DHV-42 2

A DilV-43 2

A FUNCTION: ' Containment isolation valves.

Irpractical Code Requirement Reason fair Walver Alternate Test Plan Valves required to be leak DilV-1, 2, 4, & 41.

None proposed.

tested during refueling.

Leak testing of these valves le not possible as they are part of the normal Decay lleat Removal System flew path used during refueling.

DilV-42 & 43.

No practical method to Jeak rate test these valves due to potentially high radiation area.

s a

ENCLOSURE 4 (con't)

VALVE INSERVICE INSPECTION WA1VER REQUESTS ASME Section XI - 1974 thru Summer 1975 Addenda Name: Core Flood System Valve No.'s: CFV-2, 4 ASME Class: 2 ASME Valve Category: B/C FUNCTION: Normally closed check valves which must open during emergency conditions should the Reactor Coolant System pressure drop below 600 psig.

Impractical Code Requirement Reason for Waiver Alternate Test Plan Full stroke during cold shutdown.

Should not be tested Full stroke during refueling.

during cold shutdown due to possibility of over-pressurization of the R.C.

System.

Icplementation Schedule: Alternate Test Plan is presently implemented.

.