ML19340F182

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Disapproves 801209 Request for Relief from Inservice Testing Requirements of Section XI of ASME Boiler & Pressure Vessel Code.Requests Mod & Resubmission of Relief Request
ML19340F182
Person / Time
Site: Crane 
Issue date: 01/07/1981
From: Snyder B
Office of Nuclear Reactor Regulation
To: Hovey G
METROPOLITAN EDISON CO.
References
NUDOCS 8101210244
Download: ML19340F182 (2)


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l JAN 0 71981 Docket No. 50-320

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-l Mr. Gale Hovey Vice President and Director of TMI-2 Metropolitan Edison Company P.O. Box 480 Middletown, Pennsylvania 17057

Dear Mr. Hovey:

We have reviewed your letter of December 9,1980 (TLL 645) and have determined that we cannot fully approve the attached request for relief from the require-ments of Section XI of the ASME Boiler and Pressure Vessel Code. Therefore,

we request that you modify and resubmit within 30 days of receipt of this letter your Relief Request in accord -nce with the following guidance which we believe to be more consistent with the intent of 10 CFR Part 50.55a(g)(6)(1) and with the existing plant conditions.

We note that your Relief Request would exempt all pumps and valves in the Mini Decay Heat Removal System (MDHRS) from the inservice testing requirements of Section XI of the ASME Boiler and Pressure Vessel Code until the MDHRS ns placed into use removing reactor decay heat. We agree that until the MDriRS is placed in operation the RCS/MDHRS isolation valves (MDH-V1, MDH-V2, MDH-V18 and MDH-V19) should not be opened. However, it is our position that during this same time interval moet of the other MDHRS valves should be subjected to the valve exercise test requirements of Article IWV-3000 of Section XI of the ASME Code and that the MDHRS pumps should be subjected to the inservice testing requirements of Article IWP-3000 of Section XI of the ASME Code as modified by Part B of your Relief Request and that the pump testing frequency should be at 4

least once per 92 days. The only MDHRS valves which could be considered for relief from the valve exercise test requirements during this time interval would include drain valves, vent valves and instrument root valves unless operation of any of these valves is required to obtain required testing results or if the valves are normally open in which case they should be cycled to demon-strate isolation capability. All remaining valves in the MDHRS flowpath should be exercised in accordance with the requirements of Article IWV-3000 of Section XI of the ASME Code.

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Mr. Gale Hovey Subsequent to placing the MDHRS into op2 ration, we agree that the frequency for performing the MDHRS pump and valve inservice tests could be reduced to a minimum of at least once per 6 months. During this time interval, relief from the valve exercise test requirements should be requested for the drain valves while the vent valves could be considered for relief on the same basis as above. However, all remaining MCHRS valves, including instrument root valves, should be exercised in accordance with Article IWV-3000 of Section XI of the ASME Code but at the above noted 6 month frequency.

Sincerely, k

_m ernard J. Snyd

, Program ~ Director TMI Program Office Office of Nuclear Reactor Regulation

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