ML19324B810
| ML19324B810 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/27/1989 |
| From: | James Fisicaro ARKANSAS POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1CAN108905, GL-89-04, GL-89-4, NUDOCS 8911080275 | |
| Download: ML19324B810 (34) | |
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Litne Rock AR 72203 Tel 501377 4030 October 27, 1989 1CAN198905 7 U. S. Nuclear Regulatory Commission Document Control Desk E Mail Station P1-137 l Washington, DC 20555 L
Subject:
Arkansas Nuclear One - Unit 1 H Docket No. 50-313 License No. DPR-51 Response to Generic Letter 89-04
" Guidance on Developing Acceptable Inservice Testing Programs" Gentlemen:
In Generic Letter 89-04, the Connission requested that licensees who have not had a Safety' Evaluation Report issued for their current inservice testing (IST) program review their most recently submitted IST program and implementation procedures against the positions delineated in Attachment I to G.L. 89-04 and provide a written response addressing conformance with those positions. Arkansas Power & Light Company submits the attached response addressing each position of Attachment I to G.L. 89-04 against our resubmittal of the Second Ten-Year IST Program for ANO-1 dated October 20, 1980(ICAN198809). Changes to our IST program as a result of this generic letter, including an additional relief request and cold shutdown justifications, are included. The IST Program Procedure chariges that are required as a result of this response will be implemented by March 31, 1990, and the requisite test procedures will be implemented by June 30, 1990.
Our letter of June 14,1989(2CAN068916) explained that a response to Generic Letter 89-04 for ANO-2 was not required since a SER had been issued on June 20,1985(2CNA068503).
If you have any questions regarding this response, please do not hesitate to contact me. -
Very truly yours, y h James . Fisicaro Manager, Licensing JJF/RP/lw !
Attachments l OY gwgE!Gok3 !
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U. S. NRC l Page 2 i October 27, 1989- ,
cc:- Mr. Robert Martin !
~ U. S. Nuclear Regulatory Comission !
Region IV !
611 Ryan Plaza Drive. Suite 1000 Arlington, TX 76011 l 5
NRC Senior Resident Inspector i
Arkansas Nuclear One - ANO-1 & 2 c Number 1, Nuclear Plant Road :
Russellville, AR 72801- -
Mr. C. Craig Harbuck l NRR Project Manager, Region IV/AN0-1 V. S. Nuclear Regulatory Comission :
NRR Mail Stop 13-D-18 One White Flint North '
11555 Rockville Pike Rockville, Maryland 20852 ]
i Mr. Chester Posiusny l NRR Project. Manager, Region IV/ANO-2 ;
U..S. Nuclear Regulatory Comission :i NRR Mail Stop 13-D-18 i
' One White Flint North 11555 Rockville Pike .
Rockville, Maryland 20852 e
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! ATTACHMENT
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5 I- RESPONSE TO THE POSITIONS I
OF ATTACHMENT 1 TO l
GENERIC LETTER 89-04
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1 .. - ., j GL 89-04 Position 1-- Fuli Flow Testing of Check Valves and Position 2 - A ternative to Full Flow Testing of Check Valves I
RESPONSE
- Check valves that cannot be full-flow tested quarterly are either full-flow tested during cold shutdowns or are disassembled daring refueling outages. l In our October 20, 1988, letter resubmitting-the ANO-1 Second Ten Year IST Program, relief requests (RR) for certain valves for disassembly (as listed below) were provided. AP&L has reevaluated the ability to full-flow test ;
these valves and has determined that they can be tested in accordance with ,
- the ASME code only when the plant is in cold shutdown. Therefore, the ;
relief requests for those valves are no longer applicable, while the ;
associated Cold Shutdown justifications are noted below and are attached for :
NRC review. A Cold Shutdown justification is also required for the 1 MU-66A/B/C/D valves which were added to the plant subsequent to our October, J i
' 1988 submittal, P
Valve Number Cold Shutdown Justification RR*
MU-19-A. 19 12 MU-19-B 19 12 MU-19-C 19 12 MU-1211 20 13 t 13 t MU-1212 20 MU-1213 20 13 MU-1244 20 13 MU-1215 20 13 MU-34-A 21 11 '
MU-34-B 21 11 MU-34-C 21 11 .
MU-34-D 21 11 MU-66-A 21 MU-66-8 21 MU-66-C 21 MU-66-D 21 MU-22-A 22 15 MU-22-B 22 15 ,
MU-22-C 22 15 ;
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IE0iEI'~~ihesereiiefrequestsweresubmittedtotheNRCbyletteedated October 20, 1988 (ICAN198809), ANO-1 Second Ten Year Resubmittal, Pump and Valve Inservice Testing Program and are attached for reference.
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Since they are now full-flow tested on a monthly basis, the relief requests' previously submitted for the following check valves are also' no longer i applicable:
Valve Number (s) Relief Request
- j FW-10-A/B 18 I FW-61 21 J FW-62 21 For valves that cannot be full-flow tested ANO-1 has a sample disassembly program for check valve inspection. Currently, disassembly of fifty percent of the check valves in a system during.each refueling outage is performed. 's The check valves inspected are on a refueling outage rotation such that all the check valves which cannot be full-flow tested are disassembled and >
' inspected over'a two refueling outage cycle. If a potential generic problem is discovered during a check valve inspection, all other similar valves will be disassembled and inspected in the same refueling outage.
Listed below are the remaining valves delineated in our October,1988, letter which cannot be full-flow tested and whose relief requests are still applicable. -
Valve Number (s) Relief Request
- CF-1-A/B 6 ,
DH-14-A/B 7 '
DH-13-A/B 8 '
DH-17 8 DH-18 8 Reactor Internal 9 Vent Valves BW-2/BW-3 14 BW-4-A/B 16 17 BS-4-A/B SW-11 19 SW-13 19 FW-13-A/B 20 CS-293 23 CS-294 23 CA-61 25 CA-62 25 IbbiEI ihbse~eliefrequestsweresubmittedtotheNRCbyletterdated r -
October 20, 1988 (ICAN198809), ANO-1 Second Ten Year Resubmittal, .
Pump and Valve Inservice Testing Program and are attached for reference.
GL-89-04 Position 3 - Back Flow Testing of Check Valves l
RESPONSE
Check valves in the applications listed in Position 3 were reviewed to determine if they have a safety function in the closed direction. Most of the check valves are already being back-flow tested during power operations, i cold shutdown, or refueling outages. However, the review indicated two sets of valves, FW-61/62 and MU-19-A/8/C, which are currently forward-flow '
tested, but should also be back-flow tested. The test procedures will be revised by-June 30, 1990, to back-flow test these valves during power operations.
GL-89-04 Position 4 - Pressure Isolation Valves
RESPONSE
The pressure isolation valves (PIVs) for ANO-1 were identified in AP&L's response to Generic Letter 87-06 dated July 30, 1987 (OCANp78716) and are listed below. These valves are included in the IST program and are either leak-rate tested er leak tightness is demonstrated during plant operation. .
Valve Number (s) Type Valve Testing DH-14-A/B Check
- Monitored during power DH-13-A/B Check
- operations and tested DH-17 Check
- during each plant heatup DH-18 Check
- from cold shutdown.
CF-1-A/B Check Core flood tank pressure and l 1evel monitored during power operation.
CV-1051 MOV Pressure monitored during CV-1410 MOV power operations and leakage checked on each startup from '
cold shutdown (interlocked to protect decay heat removal I
system from reactor coolant system pressure).
DH-14-A/B are individually leak-rate tested during each plant heatup from cold shutdown. Relief Request 8 requested that DH-13-A/DH-17 and DH-13-B/DH-18 be leak rated tested as sets rather than individually, since these valves are in parallel piping configurations and cannot be leak-rate i
tested individually. Surveillance of the reactor coolant pressure boundary is maintained for all of the above valves by a reactor coolant
- system inventory balance that is evaluated daily.
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- NOTE: PIVs included in the ANO-1 Technical Specifications.
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i GL-89-04 Position 5 - Limiting Values of Full-Stroke Times for Power l Operated Valves
RESPONSE
Based on the NRC guidance on this position, to determine a reference stroke time for ANO-1 power operated valves, AP&L intends to average the last four stroke times for each valve. If these stroke times are consistent, this average will be used as a reference value. If there are wide discrepancies in the last four readings, prior readings will be reviewed and analyzed in order to determine an average reference value. The reference value will be multiplied by 1.5 in order to determine a limiting value for operability.
This limit will be compared to the existing analysis limit for operability to determine if a more restrictive value is appropriate.
ANO-1 will continue to use a multiplier of 1.25 to establish a limiting value for taking corrective action. When this limit is violated, test frequency is increased to monthly, and the valve is identified for maintenance. If a valve can only be tested during cold shutdown and the testing is not within normal limits, then maintenance or an analysis will be performed before the unit returns to power operations.
GL-89-04 Position 6 - Stroke Time Measurements for Rapid-Acting Valves
RESPONSE
This item is addressed by several relief requests. Relief Request 2* was a generic relief request for valves classified as rapid-acting. In that relief request, AP&L proposed to assign a normal stroke time limit of 2 seconds to these valves. Relief Request 4* to IWV-3813 proposed comparing stroke times to baseline values. An additional Relief Request 30 is ,
included in this response for emergency diesel generator system valves.
- NOTE: These relief requests were submitted to the NRC by letter dated October 20, 1988 (ICAN198809), ANO-1 Second Ten Year Resubmittal, Pump and Valve Inservice Testing Program and are attached for reference.
c GL-89-04 Position 7 - Testing Individual Control Rod Scram Valves in Boiling Water Reactors (BWRs)
RESPONSE
This item is not applicable to ANO-1, 1 GL-89-04 Position 8 - Starting Point for Time Period in TS ACTION Statements ;
RESPONSE
ANO-1 complies with this position. The surveillance procedures state that when a Jump or valve fails a limiting value, it is immediately declared !
inopera)1e and corrective action is initiated. If an obvious instrument problem (no flow indication, pegged high, etc.) is observed at the initiation of a test, a test gage may be used or the test may be cancelled until the instrument can be repaired. In this case, the pump will not be declared inoperable until test data can be obtained or until the surveillance interval is exceeded.
GL-89-04 Position 9 - Pum) Testing Using Minimum-flow Return Line With or '
Witlout Flow Measuring Devices l
RESPONSE
With the exception of the emergency diesel generator fuel transfer pumps, ANO-1 utilized an instrumented flow path wher conducting quarterly partial and full-flow tests of safety-related pumps. Relief Requcst 28* requested relief.from measuring flow through the emergency diesel generator fuel transfer pumps.
GL-89-04 Position 10 - Containment Isolation Valve Testing L
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RESPONSE
All containment isolation valves requiring Appendix J Type C tests will be included in the ANO-1 Inservice Testing Program. The program procedure changes will be completed by March 31, 1990.
GL-89-04 Position 11 - IST Program Scope ,
RESPONSE
The examples of items identified in this position as frequently omitted from IST programs were reviewed for applicability at ANO-1. Valves CV-1428 and CV-1429, decay heat cooler outlet valves are presently maintained in a locked position. These valves will be included in the IST program when no longer maintained in a locked position. Valves CV-1432 and CV-1433, decay heat cooler bypass valves, will be included in the IST program. These four valves have been identified as control valves that have a required fail-safe position. No cther valves or pumps were identified as applicable to this item.
IN0TEI~ThI~leiiefrequestwassubmittedtotheNRCincorrespondence s
dated October 20, 1988 (1CAN198809), ANO-1 Second Ten Year Resubmittal, Pump and Valve Inservice Testing Program and is attached for reference,
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. o ASME Section XI Verify forward flow operability and' reverse i
? Quarterly Test flow closure.
Requirements:
Cold Shutdown Full stroking these-valves during power operation ,
Test Justification: would exceed the letdown flow rate. A high !
pressurizer level trip of the reactor could result a from the excess flow into the RCS. i l- Quarterly Part These valv'es are' partial stroke tested' quarterly. .
Stroke Testing. ,
. Cold Shutdown The ability of these valves to full stroke open n Testing: will be verified by. flow testing these valves 5 during cold shutdowns.
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System:- Makeup System Valves: MU-1211. MU-1212, MU-1213, MU-1214, and MU-1215 E Category: C Function: These check valves are in the high pressure injection line to.the RCS.
ASME Section XI Verify forward flow operability and reverse flow Quarterly Test ' closure.
. Requirements:
F -Cold Shutdown- Full. stroking these valves during normal power Test Justification: ~ operation would require a flow rate into the RCS that would exceed the letdown flow rate. A high pressurizer level trip of the reactor could result from the excess flow into the RCS.
Quarterly Part None.
Stroke Testing:
Cold Shutdown The ability of these valves to full stroke open Testing: will be verified by flow testing during cold shutdown.
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i System: Makeup System J Valves: MV-34-A, MV-34-B, MV-34-C, MV-24-0. MU-66-A, MV-66-B, MV-66-C. and MU-66-D l
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t RCS through these check valves during engineered safeguards actuation.
ASME Section XI Verify forward flow operability and reverse Quarterly Test flow closure.
Requirements:
Cold Shutdown Full stroke exercising these valves during normal ;
Test Justification: operation would require approximately 250 GPM of 1 RCS makeup. This flow rate would exceed letdown flow and possible lead to a reactor trip on high ,
pressurizer level. Additionally, testing -these i '
valves would impose unnecessary thermal cycles on the HPI nozzles which could cause premature failure -
of the HPI nozzles. ,
Quarterly Part None. ]
Stroke Testing: '
Cold Shutdown The ability of these valves to full stroke open l Testing: and closed will be verified by flow testing during cold shutdowns.
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System:. Makeup System Valves: MU-22-A, MU-22-B, and MU-22-C Category: C Function: These valves provide minimum recirculation flow for l- makeup pumps during normal operation and certain ,
accident conditions. During accident conditions, the recirculation path is automatically closed and the valves prevent backflow through a non-operating recirculation lines. If the makeup flow is 4- required to be throttled, the recirculation line is unisolated and these valves open to ensure minimum flow for the operating pumps.
ASME Section XI Verify forward flow and reverse flow closure.
Quarterly Test Requirements:
Cold Shutdown There are no flow measuring devices in the makeup Test Justification: pump recirculation lines.
Quarterly Part These valves are partial stroke tested quarterly.
Stroke Testing:
Cold Shutdown The ability of these valves to full stroke open Testing: will be verified by flow testing during cold shutdown. The flow through these check valves is calculated by measuring the rise in the makeup tank level. During power operations, the makeup tank discharge is not isolated. Hence, the flow through these check valves cannot be verifie during power operations.
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System: . Emergency Diesel Generator System Valves: SV-5218, SV-5233, SV-5237, SV-5239, CV-3806 CV-3807. CV-5218, CV-5233, CV-5237, and CV-5239
' Category:' 8 1 ASME Section XI Stroke time valves in accordance with IWV-3413 Quarterly Test and Relief Request'#4.
Requirements:
Relief Requests: These valves do not have independent actuation and J hence cannot be independently timed. They are interlocked with the Emergency Diesel Generator and stroked open when the EDG-is started. The EDG must be at rated voltage within 15 seccnds of receiving an actuation signal. - A successful start of the EDG (within 15 seconds of signal) constitutes a successful stroke test of these valves.
Quarterly Part These valves are full stroke tested quarterly.
Stroke Testing:
Cold Shutdown These valves are full stroke tested quarterly.
Testing:
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p-f EWP880116 L e Relief Request - 2 f-g System: All L Valve: All Ca te go ry: A or B Fuc?( an: NA f ASME Section XI Quarterly Test
; Requirements: The ASME cade states that the limiting value of full-stroke time of power operated valves is that time interval from l initiation of the actuation signal to the end of the actuating cycle.
Relief Request: The NRC has stated that for fast-acting valves a limiting time of 2 seconds can be assigned as the valve actuation time. Fast acting valves are valves.with actuation times of less than 2 seconds. AP&L proposes to classify certain valves as fast acting valves and assign a normal stroke time limit of 2 seconds to the valves so classified. Quarterly Part Stroke Testing: NA Refueling Testing: NA l l l 1 i l' l l 29
e ,,v, o- EWP880ll6 [ J Relief Request - 4 Systems All ; Valve All Category: A and B Function: NA ASME Section XI Quarterly Test Requirements: The ASME codes states that if, for power cperated valves, , an increcse in stroke time of 25% or more from the previous test for valves with full-stroke times greater than 10 second er 50% or more for valves with full-stroke times less than or equal to 10 seconds is observed, test frequency shall be increased to once each month until corrective action is taken Relief Request: The ASME code requires the maintenance of a running file on previous test stroke times. This file would mean that surveillanco procedures would have to be revised monthly. Also, the code would allow a valve to degrade without , flagging it. Finally, maintenance of a running file increases the chances of making clerical errors. AP&L , proposes to establish a baseline stroke time and any , stroke time that is 25% greater (50% greater for valves with a baseline of 10 seconds or icss) than this baseline streke time will cause the test frequency to increase to monthly. Quarterly Part Stroke Testing: NA Refueling Testing: NA l i 1 i
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System: Reactor Coolant System Valve CF-1A and CF-1B Category: C i Function: These are check valves in lines between the core flood tanks and the reactor. AS:!E Section X1 Quarterly Test
~ Requirements: Verify forward flow operability and reverse flow closure.
Relief-Request: Flow cannot be extablished through these valves in normal operation because the differential pressure between the RCS (appro::imately 2250 psig) and the CFTs (approximately . 600 peig) acts to maintain check valves DH-14A and DH-14B ' closed. These check valves are in series with CF-1A and CF-13 respectively, therefore preventing flow through CF-1A and CF-1B from CFTs. . Quarterly Part Stroke Testing: None. These valves cannot be opened during normal operation due to the differential pressure between the RCS and CFTs. Refueling Testing: The ability of these valves to full stroke open and close vill be verified either by visual inspection, flow, or external means (ultrasonics). If these valves are visually inspected, then CF-1A will be inspected during even numbered refueling cutages and CF-1B will be inspected during odd numbered re-fueling outages. 9 33
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l System: Reactor Coolant System t L valves DH-14 A and DH-14B Category: C F..
; Function: These check valves are in the LP injection line to the reactor.
o p ASME Section XI Quarterly Test
; Requirements: Verify forward flow operability and reverse flow closure.
Relief Request: Flow cannot be established through these valves in normal p operation because the differential pressure between the RCS (approximately 2250 peig) and the CFTs (approximately 600 psig) acts to maintain DH-14A and DH-143 closed. Quarterly Part Stroke Testing: None. These valves cannot be opened during normal operation due to the-differential pressure between the RCS and CFTs. Refueling Testing: The. ability of these valves to full stroke open and close will be verified either by visual inspection, flow, or external means (ulcrasonics). If these valves are visually inspected then DH-14A will be inspected during even numbered refueling outages , and DH-14B will be inspected during odd numbered refueling outages. l t 1 34
t ~* , EWP880116 Relief Request - 8 ! I System: Reactor Coolant System l Valve: DH-13A, DH-13B, DH-17, and DH-18. Category: AC Function: These check valves are located in the lines between the decay heat removal pumps and the reactor vessel. These check valves protect the decay heat removal pumps from RCS/CFT pressure. ASME Section XI Quarterly Test Requirements: Verify forward flow operability and reverse flow closure. Relief Request: These check valves are in a parallel pipe configuration (with two valves in series in each pipe run). Full flow. can be verified through the system but not through each set of valves. There are not any isolation valves in this parallel configuration. Also, these valves are required to be leak rate tested.* There is not a way to leak test these valves individually. These valves will be leak rate tested as a set and the maximum leakage through the set will be based on the maximum leakage through the most limiting valve. ! Quarter 1r Part Stroke !=tting: None. Due to the differential precsure between the RCS and the discharge of the decay heat removal pumps, these valves cannot be partial stroke tested during power operations. These valves are partial stroke tested during cold shutdowns. , Refueling Testing: The ability of these valves to full stroke open and close j will be verified either by flow, visual inspection, or ! external means (ultrasonics). If these valves are visually inpsected then DH-13A , and D!!-17 will be inspected during even numbered outages and DH-13B and DH-18 will be inspected during l odd numbered refueling outages. l i
- NOTE: These valves are leak tested during plant startup.
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Relief Request - 9 ! 5 k System: Reactor Coolant System , i Valve: Reactor vessel internal vent valves. , Catego ry: C u Function: The reactor internal vent valves are used for relieving the pressure generated by steaming in the core following a LOCA so that the core will remain sufficiently cooled. ASME Section XI - Quarterly Test " Requirements: Verify forward flow operability and reverse flow closure. Relief.
- Request: The reactor vessel internal vent valves are only accessible and testable when the reactor head is off. Normally, the reactor head is only removed during refueling outages.
Quarterly Part Stroke Testing: None. These valves are inaccessible during power operation. Refueling Testing: These valves will be manually stroke tested during refueling outages utilizing a spring gauge to measure their resistance. . I ! l l e 36
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l Relief Reauest - 11 System: Makeup System l-Valve: MU-34A, MU-34B, MU-34C, and MU-34D ; Category: C
' Function: HP injection water is admitted into the RCS through these check valves during E.S. actuation.
ASME Section XI , Quarterly Test l - Requirements : Verify forward flow operability and reverse flow closure. . Relief Request: Full stroke exercising these valves in normal operation ' would require approximately 250 GPM. This flew rate would e:.ceed letdown flow, and possibly lead to a reactor trip on high pressurizer level. Also, testing these valves would impose unnecessary thermal cycles en the HPI nozzles,. which could cause premature failure of the HPI nozzles. Quarterly Part Stroke Testing: None. Refueling ' Testing: - The ability of these valves to full stroke open and close will be verified either by visual inspection, flow or l external means (ultrasonics). l If these valves are visually inspected then MU-34A and MU-34B sill be inspected during even numbered refueling outages and MU-34C and MU-34D will be inspected during odd numbered refueling outages, i ( 8 38
, 'EWP880116 i
Relief Request - 12 !
' i System: Makup System Valve: MU-19A, MU-19B, and MU-19C l Category: C Function: These are the primary makeup pump discharge check valves. j ASME Section XI -
Quarterly Test Requirements: Verify forward flow operability and reverse flow closure. Relief Request: Full stroking these valves during power operation would exceed the letdown flow rate. A high pressurizer level-
. trip of the reactor could result from the excess flow into the RCS. >
Quarterly Part Stroke Testing: These valves are partial stroke tested quarterl;. Refueling I Testing: The ability of these valves to full stroke open and close will be verified either by visual' inspection, flow, or external means (ultrasonics). If these valves are visually inspected then iiU-19A and-MU-19B will be inspected during even numbered refueling
, outages and MU-19C will be inspected during odd numbered refueling outages.
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t Relief Request - 13 I System: Makeup System , i : Valv,e : KU-1211 MU-1212. MU-1213 MU-1214, and MU-1215 , L Category: C 7 Function: These check valves are in the HP injection line to the RCS. l I' ASME Section XI
; Quarterly Test Requirements: Verify forward flow operability and reverse flow closure.
Relief Request: Full stroking these valves during normal power operation would require a flow rate into the RCS that would exceed the letdown flow rate. A high pressuri er level trip of the reactor could resul*. from the excess flow into the RCS. quarterly Part Stroke Testing: None. These valves are partial stroke tested during cold shutdown. ; e Refueling Testing: The ability of these valves to full stroke open and close , will be verified either by visual inspection, flow, or , external means (ultrasonics). , If these valves are visually inspected then MU-1211 MU-1212, and MU-1213 will be inspected during even numbered refueling outages and MU-1214 and MU-1215 will be inspected during odd numbered refueling outages. - 1 I 1 l l G 40
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e , 1 [l l l Relief Request - 14 , System: Makeup System l Valve: BW-2 and BW-3 Ca tegory: C , [ Function: These stop check valves are in the supply lines to the primary makeup pumps. ASME Section XI Quarterly Test Requirements: Verify forward flow operability. Relief Request: Full stroking these valves during normal power operation would require a flow rate into the RCS that would exceed the letdcwn flow rate. A high pressurizer trip of the i reactor coulu result from the excess flow into the RCS. Also, it would put highly borated water in the RCS
- c. causing a power transient.
Quarterly Part [ Streke Testing: None. These valves are partial stroke tested during. cold shutdown. Refueling Testing: The ability of these valves to full stroke open will be verified either by visual inspection, flow, or external means (ultrasonics). If these valves are visually inspected then BW-2 will be inspected during even numbered refueling outages and BW-3 will be inspected during odd numbered refueling outages. e 41
r 1.o EWP880116 Relief Request - 15 System: Makeup System j Valve: MU-22A, MU-22B, and MU-22C Category: C Function: These valves provide minimum recirculation flow for makeup pumps during normal operation and some accident situations, During accident conditions the recirc path is automatically closed and the valves prevent backflow through a non-operating recirculation line. If the makeup flow is required to be throttled then the re-circulation line is first unisolated and then these valves must open to insure minimum flow for the operating pumps. ASME Section XI Quarterly Test Requirements: Verify forward flow and reverse flow closure. Relief Request: There are not any flow measuring devices in the makeup pump recirculation lines. , Quarterly Part Stroke Testing: None. Refueling Testing: The ability of these valves to full stroke open and close will be verified either by visual inspection, flow, or i external means (ultrasonics), j If these valves are visually inspected then MU-22A and MU-22B will be inspected during even numbered refueling l outages and MU-22C will be inspected during odd numbered refueling outages. I f l I i l i l i l E ; I i i \ 42 L _ 1
Wa o rWPasolls .i L l L, Relief Request'- 16 System: ' Decay iest hemoval System Valves BW 4A and BW-4B 'I
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Cat ego ry: C , Function: These check valve. are in the suction line to the decay. '. heat removal pumps. [ l" ASME Section XI Quarterly Test !
;. Requirements: Verify forward flow operability and reverse flow closure.
Relief i Request: To full stroke these valves would require running the HPI, { LPI, and building spray pumps simultaneously.. Running , the HPI pumps with water from the BWST would put highly l
, borated water into the RCS which would put the RCS outside ;
I the boron limits outlined in_the Technical Specification. ! t Qutrterly Part j Stroke Testing: These check valves are 60% flow tested quarterly,- , Refueling i u Testing: The ability of these valves to full stroke open will be- ! verified either by visual inspection, flow, or external mesnn (ultrasonics). ! If these valves are visually inspected then BW-4A will be inspected during even c. mbered refueling outages.and BW-4B will be inspected during odd numbered refueling outages. ' i I e f h [ t l f i i t
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, Relief Request - 17 j
[. I' ',r System: Building Spray System j l Valves BS-4A and BS-4B j I f- [ Category: C t Tunction: These valves are the building spray pump discharge check valves. These valves also act to maintain a water level i in the building spray piping. j ASME Section XI [ Quarterly Test
. Requirements: These valves are tested to verify forward flow operability. ;
Relief ( Request: Stroking these valves would spray borated water into the reactor building causing decontamination problems and possible equipment damage, i i Quarterly Part I Stroke Testing: None. See relief request segment, j
)
, Refueling l Testing: These valves will be disassembled, visually examined, and ;
manually stroked during refueling outages. BS-4A will be i disassembled during even numbered refueling outages, while i BS-4B will be disassembled during'ood refueling outages. , [
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o .,, EWP880116 I:elief Request - 18 System: Emergency _Teedwater System Valve TW-10A and TW-10B Category: C Tunction: These are the EFW pump discharge recire check valves. When the check valve is closed the recire. line is open. When the check valve. closes the recirc. line is isolated and flow is routed to the steam generators. TV-10A is the 'A' ETW pump discharge check valve while TW 10B is the 'B' ETW pump discharge check valve. ASME Section XI Quarterly Test Requirements: Verify forward flow operability. Relief Request: Interim relief from full stroke exercising these valves is needed until the next refueling outage (1RS) when flow measuring indication will be adJtd to the recire. lines. Presently, there is not a way to quantify flow through-the recire. lines. Quarterly Part Stroke Testing: When the flow orifices are installed the valves will be full stroke tested monthly. Refueling Testing: NA t l l
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'l System Emergency Feedwater System j Valvet SW-11 and SW-13 [
Catego ry: C i Function: SW-11 is in the suction line that provides loop 1 service ; water to the ErW pumps. SW-13 is in the supply line that' supplies loop 2 service water to the ETV pumps. ; I A3ME Section XI ' I Quarterly Test Requirements: Verify forward flow operability and reverse flow closure. g Relief Request: Stroking this valve during power operation would admit ! service water into the feedwater system which'will i adversely affect the quality of the steam generator j chemistry leading to potential tube failure. i t Quarterly Part : Stroke Testing: None. See answer to Relief Request segment. '; Refueling l Testing: SW-13 is opened up and manually stroke tested during l even numbered refueling outages. SW-11 is opened up i and manually stroke tested during odd numbered refueling outages, j h f i
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EWP840116
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i j- System Emergency Teedwater System :
> t Valves FW-13A and TW-138 ! ! Catego ry: C Function: These check valves are in the EFW pipes to the steam !
generators. ASME Section XI i Quarterly Test r Requirements: Verify forward flow operability and reverse flow closure, r Relief f Request: These check valves cannot be exercised during normal operation because cold water would be sprayed onto steam i senerator tubing and tube degradation could result. ! These valves sre not full stroke tested during cold ! shutdown in order to minimee the effect un SG chemistry. l Quarterly Part i Stroke Testing: None. See relief request segment for explanation. 7 These valves are partial stroke tested during cold. [ shutdown. ., i Refueling [ Testing: The ability of these valves to full stroke open will i be verified either by visual inspeciton, flow, or , external means (ultrasonics). If these valves are l visually inspected, then FW-13A will be opened during ; even numbered refueling outages and FW-13B will be j opened during odd numbered refueling outages. j i
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o oo EWP440116 ; D ' Relief Request - 21 l System: Emergency Teedwater System ! Valves FW-61 and W-62 ! Category: C Function: These check valves are in the EW pump recire. lines. '[
., r ASME Section XI -
Quarterly Test l Requirements: Verify forward flow operability. .'; Relief [ Request: Interim relief from full stroke exercising these valves 'l 1s needed until the next refueling outage (IR6) when flow : measuring indication will be added to the recirc. lines. Presently, there is no installed way to quantify flow c through the recire. lines. , Quarterly Part ; Stroke Testing: After the flow orifices are installed these valves will be 't full stroke exercised monthly. lt Refueling l Testing: NA ; t [ f r 6
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ww a , , EWPS80ll6 Relief Request - 23 System Emergency Feedwater l Valve: CS-293 and CS-294 j Category: C ! Tunction: These are parallel check valves in the emergercy feedwater ' suction line from the condensate storage tank. j ASME Section XI I Quarterly Test j Requirements: Verify forward flow operability and reverse flow closure. ; Relief , Request: These two check valves are in a parallel pipe configuration. ! Tull flow can be verified through the system but not through I cach individual valve. -There are not any isolation valves ; in this parallel pipe configuration. Quarterly Part , Stroke Testing: These valves are partial flow tested quarterly. { l Refueling ; Testing: The ability of these valves to full stroke open and i closed will be tested by either flow, visual inspection, ! or external means (ultrasonic). ) If these valves are visually inspected then CS-293 will i be opened during even numbered refueling outages and j CS-294 will be opened during odd numbered refueling j outages. i f f 1 i l i
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Relief Request - 25 !
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Sys t.em: Chemical Addition ; i Valve: CA 61 and CA-62 Cate go ry: C i Function: These valves prevent BWST water from flowing into the sodium hydroxide addition system. These valves also admit sodium hydroxide to the building spray system during its operation. ; ASME Section XI : Quarterly Test Requirements: Verify forward flow operability and reverse flow closure. Relief Request: Full stroke exercising these vsives in power operation 1 would upset RCS pH control. Addition of sodium hydroxide ' into the RCS would also lead to an increase in radio- ' activity levels in the RCS, ; Quarterly Part i Stroke Testing: None. Refueling Testing: The ability of these valves to full stroke open and close , will be tested by either flow, visual inspection, or external means (ultrasonic). t If these valves are visually inspected then CA-61 will be inspected during even numbered refueling outages and CA-62 ; will be inspected during odd numbered refueling outages. r l l l r 52}}