ML20024H398

Forwards Rev 8 to Inservice Testing Program Plan for Pumps & Rev 9 to Inservice Testing Program Plan for Valves.

ML20024H398
Person / Time
Site:	Byron
Issue date:	05/23/1991
From:	Schuster T COMMONWEALTH EDISON CO.
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20024H399	List: ML20024H398 ML20024H403 ML20024H404
References
NUDOCS 9106030256
Download: ML20024H398 (15)

Text

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0 Ccmmtnwealth Edisen 1400 Opus Piece C p Downers orove, Illinois 60515

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( L M May 23, 1991 (2'@

Dr. Thomas E. Murley, Director l Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commis

ion Nashington, D.C. 20555 Attn: Document Control Desk

Subject:

Byron Units 1 and 2 Inservice Testing Program Plan for Valves Relief Request VR-4 flRC DocLet Jios_50-454 and 50-455

Reference:

a) September 14, 1 00, NRC Supplemental Safety Evaluation '

Report issued for review of Byron !nservice Testing Pump and Valve Programs, revisions 7 and 8.

b) April 24, 1991 teleconference between Dyron Station personnel, T. Schuster and NRC Staff personnel regarding Containment Spray check valve testing.

l c) May 2, 1991 teleconference between T. Schuster and A. Hsia regarding expedited transmittal of IST Program in order to resolve NRC staff open items.

d) May 7, 1991 teleconference Netween Byron Station personnel, A. Checca and NRC Staff personnel regarding remaining NRC Staff open items.

Dear Dr. Murley:

Relief Request VR-4 from the Byron Station Inservice Testing Plan for Valves, is being provided for your review. This submittal is in response to the NRC Staff verbal request to provide additional justification for relicf from full flow / full stroke exercising the C5008A/B, containment spray M containment ring header check valve, and CS003A/B, containment spray pe L discharge check valve. Relief Reque-t VR-4 has been revised to includ.

I additional justification. In addition, information regarding backflow testing i and the sample disassembly plan previously contained in Relief Requests VR-18 and VR-19, has been transferred into VR-4 in response to NRC comments.

The improved justification provided in VR-4 and additional considerations are summarized below:

1. The C5008A/B and CS003A/B valves will be removed and inspected in lieu of full flow testing during refueling cycles, in accordance with the frequency specified in VR-4.

//

i 2. Valve removal is acceptable to demonstrate operability for the l following reasons:

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ZNLD/651:26 M O6030256 m 23 PDR ftOOCK 05000454 hr 0 022 P enn i

Dr. Thomas E. Murley May 23, 1991 L

p a) Removal and re-installation of the check valves will be performed t,y maintenance personnel using standard maintenance procedures, including applienble quality control hold ooints.

L b) Visual inspection, by qualified Technical Staff Engineers, will assure freedom of travel by physically deflecting the valve disks to the full open position, c) Independent verification by qualified personnel, including Technical Staff Engineers, of proper valve installation, includir,g orientation of disk (vertical) and direction of flow, d) Performance of a Technical Specification required post maintenance 10 CFR 50, Appendix J, Type C local leak rate test upon re-installation of the CS008A/B valves. This test also serves to demonstrate proper valve orientation by verifying valve seat integrity (Back Seat Test),

e) The CS003A/B valves undergo quarteriy partial stroke testing, with the CS pump running in miniflow, which verifles proper valve operation and orientation between visual examinations, f) The valve internals are NOT dissassembled to verify operability. The valve is removed only to verify proper operation of the disk.

g) The C5008A/B valve is not challenged between inspections.

Forced flow never passes through the valve between inspections, therefore, the potential for degradation is limited.

l h) Any water present tri the CS008A/B valve is drained once per refueling outage in order to remove the valves and/or perform i local leak rate testing. This minimizes any risks associated with stagnant water in the line.

1) Inspections during the-previous 5 refueling outages have shown the valves to be in a pristine condition.

' 3. Full flow exercising is not considered a viable option for the following reasons:

a) Due to the arrangement of the Containment Spray ring header risers, separate spool pieces and piping systems would be required to be f abricated and welded to perform the testing.

These temporary piping systems, approximately 45 feet in length per containment spray riser, would then have to be installed, removed, and stored each refueling outage.

to Protective interlocks prevent the testing of the CS pump with ring header isolation valve open. These interlocks would have to be defeated and then re-instated for each test.

ZNLD/651:27 l

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Dr. Thomas E. Murley May 23, 1991 c) The addition of approximately 3000 to 4000 gpm to the refueling cavity, with ample time to obtain flow data, would necessitate the lowering of the refuel cavity level, potentially impacting minimum Technical Specification requirements, as well as refuel cavity clarity requirements. Performance of the test after core load, w!th the refueling cavity drained, would result in the spread of large quantities of contaminated water, resulting in a significant decontamination effort. In addition, the Reactor Vessel Head may have to be removed to prevent contact with borated water spray.

Since th): relief request has the potential of significantly impacting the September, 1991 refueling outage for Byron Stations, an expedited review and approval is requested. Completion of NRC review of revised Relief Request

, VR-4 is requested by August 15, 1991. Attached as Enclosure 1 is a vendor drawing of the CS003A/B and CS008A/B check valves. 7t is provided in response to an NRC staff request. Please direct any questions you may have concerning this matter to ti.is office.

Respectfully,

%J9 Terence K. S:huster Nuclear Licensing Administrator

Enclosures:

1) Drawing of CS003A/B and CS008A/B valves

.2) Revised Relief 'equest VR-4 (Rev. 10a) cc: A. Hsia - NRR Project Manager H. Kropp - Byron Resident Inspector A. Bert Davis - Regional Admin. RIII l

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[ Enclosure 2 PELIELIlEQUESLR4

1. V etlye_1hnbe r : ICS003A 2C0003A ICS003B 2CS003B ICS008A 2CS00BA ICS008D 2CS008H

2. N umb.c f_nLhems : 8

3. ASME_ cmc __fatigory : AC & C

4. AStiE_CMeu S e c.tian lLEe gtti r.cmen t s :

Exercise check valves to the position required to fulfill t.he i r function (open=Ct closedsBt), unless such operation is not practical during plant operation, per IWV-3522.

5. 5 Ash Lut_Ec1L21:

These valves cannot be full flow tested as a matter of course during unit operat. ion or cold shutdown as water from the CS pumps would be discharged through the CS ring hendets causing undesirable effects on system components inside containment.

Additionally, the full flow testing of these check valves durinq periods of cold shutdown, using the CS pumps, would fill the reactor refueling cavi'y with contaminated water from the refueling water storage tank. The filling of the cavity, via temporarily installed large bore piping, would require the removal of the reactor vessel head so as to preclude equipment damage from borated water. The erection of temporary piping from the CS line to the reactor cavity would take an estimated r>ine to twelve shifts, or longer compared to one to two shifts for valve inspection. This estimate does not take into account the time required to drain and remove the piping from containment.

Currently, lull flow recirculation flow paths do not exist from the discharge of the CS pumps through these check valves to the refueling water storage tank. The addition of such flow paths would require extensive plant modifications to existing plant designs, including penetration of containment integrity.

Partial stroking of the 1/2CS008A, B valves using air does not provide adequate assurance of valve opert.bility and may be detrimental for the following reasons:

A. There is no corralation between air flow and angle nf disc movement.

B. Venting and drainino the apprt,priate piping quartorly may cause deposition of boric acid residuo which <ould in turn promote binding of the check valve internalr (0095D/0035D/051791) 4.6 - page 7 of 39

Rev. 10a I

I RELIE E_EEQUEST_VR:.42-_sont . I

6. Alternate Testing:

The_ A and B train valves are of the smne design (manufacturer, cize, model number, and materials construction) and have the same s6rvice unditions, including orientation, therefore they form a sample disnssembly group. .I

_ Dioup 1 Gtnugl ICS003A 2CS003A ICS003B 2CS003B Crnup 1 Group 2 1CS008A 2CS008A ICS008B 2CS008D One valve from each group, on a per unit basis, will be tested each refueling outage. If the-disassembled valve is not capable of being full-stroke exercised or if there is binding or failure of valve internals,-the remaining valve on the affected unit will be inspected.

-7. Justifica11gn:

l The 1/2CS008A,B and 1/2CS003A,B valves are removed from the system and visually examined por the strict detailed inspection requirements of the Station Check Valve Program. This inspection adequately verifles that the valves are maintained in a state of operational readiness. The valves are verified to be functional by performing a thorough visunl inspection of the valve internals and by performing a full stroke test exercise of each disc. Previous inspections of these particular valves at both Byron and Braidwood have repeatedly shown them to be in good condition.

l The wafer type design of the valve body for these valven make their removal a simple process, with little chance of damage to their internals. Also, there is no disassembly of internal. parts required; all wear surf aces are accessible by visual examination. _ Af t er inspection and -

stroke testing, the valve is reinstalled into the line and post maintenance testing is performed. The 1/2CS008A, B valves receive a containment leakage' test, and the 1/2CS003A, B valves-are partial flow tested. These tests verify proper installation of the check valves, and-the valve-inspection proceduto requires post-inspection visual examination of the check valve to insure that the pin is oriented p>operly and that l- the flow direction is correct.

i The alternate test frequency is justifiable in that maintenance history and -previous inspections of these valves at Byron. and Br aidwood stations has-shown no evidence of degradation or impairment. Industry experience, as documented in NPRDS, showed no history of problems with these valves.

A company wide check valve evaluation addressing the " E I' R I Applications Guidelines for Check Valves in Nuclear Power Plants" revealed that the location, orientation and application of these valves are not conducive to the type of wear or degradation correlated with SOER 86--03 type problems.

However, they require some level of monitoring to detect hidden problems, i

(0095D/0035D/051791) 4.6 - page 8 of 39

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... Pov. 10a RELIIr_EEQUESLYR-O_csnt .

8 Appli.cahle_Ilme_Patindi This rellet is requested once per quarter during the first ira pec tion interval.

9. ApproyALEtatus

a. Relief to disassemble in place of full flow testing granted per SER 9/15/88 for 1/2CS003A. B; relief denied por SER 9/15/88 for 1/2CS008A.

b .' Revised.to address NRC concerns in Liyron SER response 12/16/88 (Byron Station Letter 88-1321).

c. Relief to disassemble in place of full flown testing granted per j Generic Letter 89-04.

d. Revised to address NRC concerns in liyron SER 9/14/90 and to include both full flow (Ct) and backflow (Bt) test; relief granted per Generic Letter 89-04.

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(0095D/0035D/051791) 4.6 - page 9 of 39

O OY 1 Opus ae

' Downers Grove, Illinois 60515 Ih '

l 4 9, May 23,1991 d

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$ft Dr. Thomas E. Murley, Director Office Of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Document Control Desk

Subject:

Byron Station Units 1 and 2 k Inservice Testing Program for l' umps and Valves Revision 9 and 10/10a, respect vely NBC_DockeLNosJD-45LandfA455

Reference:

(a) September 14,1990, NRC Supplemental Safety Evaluat!on Report issued for review of Byron Inservice L

Testing Pump and Valve Programs, revision 7 and 8 (b) U.S. NRC Report Nos. 50-454/91003 (DRS)

& 50-455/91003 (DRS) r pertaining to Temporary Instruction 2515/109, l Inspection Requirements for Generic Letter l

89-10, Safety Related Motor Operated Valve Testing and Surveillance."

(c) April 24,1991 teleconference between Byron Station personnel, T. Schuster'and NRC Staff aersonnel regarding Essential Service Water Vlake-up, Containment Spray and Residual Heat Removal pump vibration monitoring, Containment Spray check valve testing, and Alert ranges for MOV's.

(d): May 2,1991 teleconference between T. Schuster ,

and A. Hsia regarding_ expedited transmittal of IST Program in order to resolve NRC staff open items

.(e) May 7,1991 teleconference between Byron Station personnel, A. Checca and NRC Staff personnel regarding remaining NRC Staff open items h

Dear Dr. Murley:

Attached is the Inservice Testing (IST) Program for Pumps and Valves, revision 9 and 10 respectively, for Byron Stations Units 1 and 2. In addition,in an effort to resolve identified NRC Staff open items, minor change revision 10a to the Valve Program has also been included. Enclosure 1 is a summary identifying the proposed changes to the Pump and Valve Programs. Enclosure 2 and 3 are the actual revision 9 and 10 documents for the Pump and Valve Programs, respectively. Enclosure 4 Is a summary identifying the proposed changes included in revision 10a of the Valve Program. Enclosure 5 is the actual revision 10a document, including only revised pages affected in the Valve Program. Revision lines in the far right hand margin identify each change. ,

PLB/scl:lD867:13

Dr. Thomas E. Murley May 23,1991 This transmittal of the Byron IST program, revisions 9 and 10, addresses concerns identified in References "a" and "b", the specifics of which are outlined in their respective program revision summary. The Supplemental SER of Reference "a" essentially requested a written response providing additional justification for the vibration monitoring action levels for the Essential Service Water Make-Up pumps of relief request PR-7. Relief Request PR-7 was revised to include additional justification for higher than nominal vibration levels. This position was discussed with the NRC staff in Reference "c" and is considered resolved.

The submittal of the minor revision 10a to the Valve Program is in response to NRC Staff requests durina References "d" and "e" to resolve existing NRC Staff identified open items. Not all the issues discussed during the teleconference of Reference "e" were addressed due to the nature of the issues and the time limitations olaced on delivery of this revision. Those issues must, theiefore, be addressed after ssuance of the next IST Program Safety Evaluation Report. Major open items resolved include:

1. Revision to Relief Request VR 4 to incorporate additional justification for valve removal in lieu of full flow exercising. This position was discussed with NRC Staff personnel in Reference "c", "d" and "e" and is considered resolved. In order to expedite approval of this relief request, a separate transmittal with request for approval by August 15,1991, has been submitted.

2. Revision to Relief Requests VR 2, VR-4, VR-18 and VR-19 in response to NRC Staff concerns expressed during reference (e), involved the diversity and number of systems referenced in VR-18 and VR-19. The revised relief requests provide a more logical representation for the components involved.

3. Revision to Relief Request VR-20 to incorporate NRC Staff concerns regarding ALERT ranges for Motor Operated Valves. This revision was discussed with NRC Staff personnel in Reference "d" and "e" and is considered resolved.

Commonwealth Edison personnel are appreciative of the NRC Staff attempts to resolve all open items in an expeditious manner. Please direct any questions you may have concerning these matters to this office.

Respectfully, ,

$ttf Terence K. Schuster Nuclear Licensirig Administrator Enclosures cc: A.H. Hsia-Project Manager, NRR W. Kropp-Senior Resident inspector, Byron w/o enclosures A. Bert Davis-Regional Administrator-Rill w/o enclosures PLB/scl:lD867:14

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ENCLOSURE 1 PLB/scl:lD867:15-

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I Section M Ighlg M Contents

1. Added Notes 6 and 7 See e2p)_anation of Notes 1 aEd 7_t Section M Procram Dgscription No changes to this section Section 3 2. Eragram References No changes to this section hetion M Procram Tables

1. Added Essential Service Water Booster Pump 2SXO4P See

_explap_ation f_or Note 11 Section 3.4 Notes

1. Added Note 6 on addition of Essential Service Water Booster Pumps 1/2SX04P TILig pyump in being added 19 the procram to satisfy the requirements of t_he_G_tation Blackout rule in that it ensures proper function o_f t_tLe Auxiliary Feedwgt_e_I .diegel by provid'ing cool _ing wate_I 19

%hg 9Rgth9 And g3b:.cle.

2. Added Note 7 on the testing of the Boric Acid Transfer Pumps 1/2AB03P outside the scope of the IST program Thig note was added in respongs to an HEQ concAIR expressed in the September 18, 1991 BER. JE this plB it was succested that the Doric Acid Tyr_ansfer Eumpg Igceive period inservice testina due 19 their required function during a postulated accident scenario. TD_ia note states tha_t althouch these cump3 Arg putside the official scope p_{ the IST Program their function ,;& important enough that they will receive a periodic ,nservice test.

Section 3.5 Relief Recuests

1. Remound " vertical line shaft" pump requirements from Draft celief Request PR-01 because there are no such pumps in the IST Program. Thig p_flangg was mad _e_ d to correct g defimition error. After. careful consideration it was determined that overly conservative testing pethM s were pei_nj;[ used pn some gumps categorized ag " vertical J_in.e.

s_ haft" Rumps. Careful re-consideration p_f 1_11g definiti_o_n p_f "verti.ggl line ghAf t" resulted in iba determingli.p_D that there are ng pumps in the program which fit this Agf:,ni t ion .

2. Added detailed information on OSXC2PA,B pump vibration issues as requested by the NRC September 18, 1990 SER to Relief Request PR-07. This prov: de deta:Lled informatl.oD informatiRD was o_D ine fact added ig that, cons:.derina .ts physical config_uration AAQ performance history, the hTaher v;.bration levels 191 this nitmn Arn predictable character:.stics af such A pump and are not indicative p1 abnormal ggmp dearadation.

(final) i

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section 12 0 Table 21 Contents No changes made to this section Section A21 Procram Description 1

No changes to this section i

SectiQD 421 Procram References i

1. Added NRC document: " Minutes of the Public Meetings on Generic Letter 89-04". This reference was added )ocause itvalve in ihm basis for the use 21 fixed alert rances for stroke times. Pel the cuidance 911his reference, technical position VA-04 covert 11194 alert rances Lqr valves which normally stroke in 10 secoqAR of less a_nd relief recuest VR-20 covers valves which normall.y stroke in creater than 10 seconds.

Section 423 Procram Tables

1. Moved Gata line for 1/2CC9437B up to comply with uniform appearance of the table. This is a strictly cosmetic chance.

2. Added "Bt" to Valves 1/2CC9534. This chance was madt to correct an oversicht and insure that the yglyn tables reflect actual testino practices. These valves are E t of relief recuest VR-18 which 13 approved Rer Generic Letter 89-04. They receive both a " full flow test"

("CT")~ and a "back-flow test" ("BT") durina refueline.

3. Added "Bt" to valves 1/2CC9518 This chance was made tg correct an oversicht and insure that the valve tables reflect actual testinc practices.-These valves are part 21 relief recuest VR-18 which ig aDDroved per Generic Letter 89-04. They receive both a " full flow test"

("CT") and A Hback-flow test" ("BT") durinc refueline.

4. Removed "Lt" test for 1/2CC9437B valves This chance was made to correct a tvDina error.

5. Added "Bt" to valves 1/2CS008A and B This chance was made to correct an oversicht and insure that the valve tables reflect actual testino Dracticesz These valves are disassembled and insoected RD A gamDie basis durina refuel outaces. The oversicht consisted of neclecting to note that disassembly and inspection accounts for both a

" full flow test" and a " back-flow" test.

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6. Added "Bt" to 1/2CV8113 valves This chance was made 19 correct an oversicht and insure that the valve tables reflect actual testino practices. These va;7es are part 91 rel:Lef request VR-18 which in approved Der Generig Letter 89-04. They receive bolb a "fl1M flow test" ("CT") Ang a "back-flow test"

("BTH) dur;&g refueling 2

7. Added "Bt" to 1/2IA091 valves This chance was pade tp correct an oversicht and insure that the valve tables reflect actual testina gractices. These val.yeg are War of relief recuest VR-18 which is approved ggI Generic Lettel 89-04. They receive both a "1gil flow test"

("CTH) and a "back-flow test" ("BTH) durino refuelino.

8. Removed "Xt" at "RR" from valves 1/2SI8818A-D This chgAge was made to correct an oversicht and insure that the valve tables reflect actual testina practices 2 These valvea are pail of relief recuest VR-18 which in approved ERI Generic Letter 89-04. Thgy receive both a " full flow test" ("CTH) and a "back-flow test" ("DT") d3Eing refuelina.

9. Added "Ct" at "CS" to 1/2SI8818D Thijs chance wag made to _

correct AD oversicht and insure that the y_alye tables reflect actual testing practices. These valves are part of the list in Note 9 which is in accordance wit _h ASME Bection XI IWV-35212 They receive a " full flow test"

("CT") at cold shutdown.

10. Corrected stroke directions ("O" for "Ct" and "C" for "Lt/Bt") for valves 1/2SI8905D This chance in beinq made for the sole purpose gf correctina a typino error.

11. Added "Bt" at "OP" to valves 1/2SI8919A and B Ihis chance was made tg correct an oversicht and insure that the valve tables reflect actual testina practices.

12. Added valves 1/2SX147A and B "Ft" test This valve was added due to its function to " fail open" on a Bafety Iniection sicnal and allow cooline water to bypass a non-safety related refriceration unit.

Section 4.4 Notes No changes to this section Section 4.5 Technical Approaches and Eositions

1. Modified VA-04 to document the use of fixed alert limits for stroke times of valves with reference stroke times of 10.0 seconds or less Per the guidance of reference I

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I, documpnt: " Minutes 91 itLt Public MeetingR ED Generio Letter 89-04".

Section 1.d Relief Reauesta

1. Revised VR-20 to document the use of fixed alert ranges for valves with reference stroke times greater than 10 seconds. Eper iltt-cuidance 9.1 reference document: " Minutes 21 ihn Publi.g Meetinas 2D Gener:.g Letter 89-04".

4 2. Revised VR-22 to show that the September 18,-1990 SER i

granted interim relief for either six months or to the next refueling outage whichever is longer. This chanan in purely informational.

i (final)

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