ML20011E974
| ML20011E974 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/15/1990 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9002230245 | |
| Download: ML20011E974 (3) | |
Text
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BALTIMORE GAS AND ELECTRIC CHARLES CENTER P. O. BOX 1475
- BALTIMORE, MARYLAND 21203 Gconot C CRttL February 15, 1990 v,eg p,,,
Nocttan Cm,tmov 400 eso mast U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos. ! & 2; Docket Nos. 50-317 & $0-318 Request for Relief from Relief Valve Testing Requirements in Section XI of the ASME Boiler and Pressure Vessel Code
REFERENCES:
(a) Letter from Mr. J. R. Lemons (DG&E) to Document Control Desk (NRC), dated April 6,1988, same subject (b) Letter from Mr. W. J. Lippold (BGAE) to Document Control Desk (NRC), i dated May 18, 1988, ASME Section XI Relief Valve Testing Requirements Gentlemem in the Spring of 1988, we sent References (a) and (b), which constituted a request for temporary relief from relief valve testing requirements for all ISI Class 2 and 3 relief valves with the exception of the main steam safety valves. The basis for relief was that some of the calculated relief valve setpoints at Calvert Cliffs may have been in error. Our Unit I was in a refueling outage and Unit 2 was operating. We received undocumented interim approval from the NRC at that time, in November, 1988, our architect / engineer (A/E) completed a review to verify the appropriate set pressure of these valves. Our NRR Project Manager recently asked us to reassess our situation regarding these valves and address whether relief is still required.
For Unit 2, five of the original 17 valves remain that have not been reset. These five valves wi'l be reset prior to starting up from the current refueling outage, as discussed in Reference (a).
For - Unit 1, five of the original 17 valves also still need to be reset. Two of the five valves were reset during the Spring, 1988 outage, as committed to in Reference (b).
Ilowever, the revised calculations from our A/E indicate that the set pressure must be further reduced,
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Document Control Desk February 15 1990 0
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l We request relief on these five valves.
COMPONEN'IS FOR WillCH RELIEF IS REOUESTED As Left
System Design
% Above Valve Function Relievine Pressure Pressure Desien 1-CVC-315-RV 11 Charging Pump 160 psig 150 psig
- 6.7%
Suction Relief 1-CYC-318-RV 12 Charging Pump 160 psig 150 psig 6.7%
Suction Relief I-CYC-321-RV 13 Charging Pump 155 psig 150 psig 3.3%
Suction Relief I-SI-417-RV Auxiliary 1 IPSI 2520 psig 2485 psig 1.4%
Suction Relief 1-SI-469-RV Shutdown Cooling 2493 psig 2485 psig 0.5%
Return llender Relief ASME REOUIREMENT FROM WillCil RELIEF IS REOUESTED Article IW V-3514, Corrective Action, states, "A
valve failing to function properly during test shall be repaired or replaced." These valves have not had the new required setpoints installed. We anticipate that they would relieve at a higher-than-acceptable pressure, and would therefore need repair. We are seeking relief from the requirement to repair at this time.
BASIS FOR REllEF Unit 1 is safe to onerate with these five valves at their oresent setoolnt. Our A/E has determined the effects of the potential stress on systems and components that would exist with these valves at their present as left setpoints. These effects are clearly acceptable.
These valves will be reset at the earliest reasonable and safe onnortunity:
CVC-315, 318, and 321 will be reset during the scheduled April 1990 maintenance
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outage. These valves are the relief valves in the suction lines of the three Charging Pumps. Resetting one of these valves requires removing all three Charging Pumps from service. These pumps are presently the only means of boration and are also necessary for Reactor Coolant System pressure control.
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Document Control Desk February 15, 1990 Page 3 l
Either a Technical Specification Action Statement would have to be entered (not normally done for maintenance) or the plant would have to be depressurized. This is unwarranted, given that the potential stress effects of the valve setpoints have been found to be acceptable and the valves will be reset during the April outage.
SI-417 needs a different spring to be reset to the proper value. This spring is on order. We intend to reset this valve during the scheduled April 1990 maintenance outage, anticipating the availability of the spring. If the spring does not arrive, the valve will be reset during the next Unit I refueling outage.
SI-469 will be reset during the next Unit I refueling outage. This relief valve is located on the common header for shutdown cooling suction and should be reset when an alternate cooling method for the fuel is available and temperatures and pressures are low enough to ensure personnel safety for entering this system.
These conditions will exist when refueling is taking place.
These valves should not necessarily have been reset by now. All of the valves from the original relief request were being reset as conditions and schedule permitted. Calvert Cliffs began a significant change in the approach to work control practices in 1989, emphasizing quality and safety over schedule. This caused initiatives such as the resetting of these relief valves to slow down and to be extended.
ALTERNATE TESTING No alternate testing is planned. This request is for temporary relief. None of these valves is due for surveillance prior to the anticipated resetting time.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
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GCC/DLS/bjd cc:
D. A. Brune, Esquire J. E.
Silberg, Esquire R. A.Capra, NRC D. G. Mcdonald, Jr., NRC W. T. Russell, NRC J. E. Beall, NRC T. Magette, DNR e