ML20028G168

Forwards Addl Info on Modified 821214 Code Relief Request 1 Revising Inservice Testing Program.Basis for Request Listed. Request Per ASME Section XI Iwv Re MSIVs MS-100 & MS-101

ML20028G168
Person / Time
Site:	Davis Besse
Issue date:	02/02/1983
From:	Crouse R TOLEDO EDISON CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
908, TAC-10985, TAC-11316, NUDOCS 8302070478
Download: ML20028G168 (5)

Text

Docket No. 50-346 TOLEDO

- License No. NPF-3 Rwn P cm Serial No. 908 Vce Presnjent Nuclear

'"*"8' February 2, 1983 Director of Nuclear Reactor Regulation Attention:

Mr. John F. Stolz United States Nuclear Regulatory Commission Operating Reactors Branch No. 4 Division of Operating Reactors Washington, D. C.

20555

Dear Mr. Stolz:

This letter is to transmit additional information on modified Code Relief Request No. 1, dated December 14,1982 (Serial No. 882), revising the Toledo Edison Inservice Testing Program, which was submitted by letter on May 15, 1982 (Serial No. 616).

Please find attached five (5) copies of additional information to Code Relief Request No. 1 for the Davis-Besse Nuclear Power Station, Unit No.

1, Inservice Testing Program. The subject of this relief request is the Class 2 valve testing requirements of ASME Section XI IWV, Main Steam Isolation Valves MS-100 and MS-101.

By this submittal, Toledo Edison Company requests relief from the perform-ance testing by partial stroking of Main Steam Isolation Valves (MSIV's)

MS-100 and MS-101.

The basis for this relief request is as follows:

a.

Partial stroking the valve during normal operation produces the potential for the valve to fully close. This would put the plant in an unsafe c:ndition, with no added safety benefit in performing the partial stroke test.

b.

Relief from partial stroking MSlV's have been issued to Light Water Reactors (LWR's) in the past.

c.

The cost for power replacement, if the valve would fully close during the partial stroking testing, would be approximately

$380,000, and an additional two days lost in operating time.

9302070478 830202 DR ADOCK 05000346 PDR THE TOLEDO EOISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO OHIO 43652 b

Docket No. 50-346 License No. NPF-3 Serial No. 908 February 2, 1983 Page 2 We request permission.to perform an "in lieu-of" full stroke test at hot shutdown. This package has been developed in accordance with the require-ments of the ASME-Boiler and Pressure Vessel Code,Section XI, 1977 Edition through Summer 1978 Addenda, and consists of the following document.

Additional information to modified Code Relief Request No. 1-Description _of and justification for the deviation from the requirments of ASME Section XI IWV-3412(a), Exercising Procedure.

This relief request is being re-submitted in accordance with 10CFR50.55a(g) (5)(iii). Any additions that become necessary due to modifications and changes to this program during the course of the 120 month interval, which do not meet the code testing requirements, will be implemented as needed. A fully documented notification to the NRC will be placed on the docket subsequent to implementation of approv-d changes.

Very truly yours,

$f RPC:ECC:nif encl.

j cc: DB-1 NRC Resident Inspector' Kevin Ward, NRC Region III George Johnson, NRC Bethesda, Maryland A. DeAgazio NRR Branch 4, Project Manager l

I, rr

Docket No. 50-346 License No. NPF-3 ATTACHMENT 1 Serial No. 908 February 2, 1983 MODIFIED CODE RELIEF REQUEST NO. 1 Components:

Main Steam Isolation Valves MS-100 and MS-101 Function:

Valves are required to close within 5 seconds on a safety actuation signal thereby isolating the main steam lines from the Steam Generators.

ASME Class:

2 Testing Requirements:

Partial stroke valve every three months during normal operation and full af coke valves during cold shutdown.

Basis for Relief Request:

1.

Code Test Requirements for exercising valves (Ref: ASME Code Section II, 1977 Edition through Summer 1978 Addenda):

"IWV-3412 Exercising Procedure"

"(a) Valves shall be exercised to the position required to fulfill their function unless such operation is not practi-cal during plant operation.

If only limited operation is practical during plant operation, the valve shall be part-stroked exercised during plant operation and full-stroke exercised during cold shutdown."

2.

Ramifications of Partial Stroke Code Test for Valves MS-100 and MS-101 When performing the partial stroke test specified in the code, the following additional safety action items would have to be implemented if the valve would inadvertently close past 90% open during the test.

If the MSIV continues to shut past approximately 90% open, attempt will be made to seat the " Slow Close" valve by pushing and releasing " Slow Close" button.

If this fails, the area must be evacuated. The reactor operator would be required to take the following action:

a)

Trip the reactor and carry out EP 1202.04 - Reactor Trip.

b)

Ensure that either a main foed pump is operating on the side where the MSIV is open og; start the startup feed pump.

c)

If MS-101 has closed, shif t auxiliary steam to the auxiliary boiler.

d)

If MS-100 has closed, shift gland steam to auxi:.iary steam.

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- - Docket No. 50-346 License No. NPF-3 Ser'ial No. 908 February 2, 1983 l

e)

S'aift turbine bypass valve on affected side to Hand and I

shut them.

f)

Open bypass valve (MS-101A or MS-100A) on affected side.

g)

Attempt to reopen MSIV when once thru steam generator (OTSG) and turbine header pressure are equalized within 100 poid.

h)

The " Slow Close" valve would also have to be repaired in order to reopen the MSIV (MS-100/MS-101).

1)

The cost involved if the above occurs would be approximately

$380,000 with two days lost operating time.

3.

Background Information on the Inservice Testing Program for the Davis-Besse Unit 1 Nuclear Power, Station 2

a) on May 15, 1980 Serial No. 616 a revised Inservice Inspection Testing Program was submitted to the NRC, requesting exception from the partial stroke testing during normal operation on valves MS-100 and MS-101 Page II-59.

The alternate testing stated in this submittal was to full stroke the valves during cold shutdown with a justification stated in the submittal.

3 b)

On November 14, 1980 Docket No. 50-346 Toledo Edison Company received from the NRC questions and comments on the submitted Inservice Testing Program. The NRC requested a meeting at the Davis-Besse 1 site on November 19-21, 1980 to discuss their review on the submitted Inservice Testing Program.

It should be'noted that there were no comments from the NRC relating to the code exception for.not partial stroking during normal operation valves MS-100 and MS-101.

0 c)

On December 15, 1980 Serial No. 671 revisions were made to the Inservice Testing Program based upon the results of the combined meeting NRC/ Toledo at the Davis-Besse site November 19-21, 1980. During the site meeting each relief request was discussed in detail, and we explained to the NRC personnel why we should not partial stroke valves MS-100 and MS-101.

It was agreed during that meeting that a 10% stroke on the valves in question would not increase any safety margin and the possible safety consequences if the valve should go full close during the test could cause a safety issue.

It should be noted on page II-59, the exception to partial stroking of the valves was not one of the questions that evolved from of the NRC review of the Inservice Testing Program.

5 d)

On March 31, 1981 Serial No. 702 based upon the resul,ts of several telephone conversations with the NRC and EG&G, Inc.. several editorial changes were made to the Inservice 2

1

--ev-

Docket No. 50-346 License No. NPF-3 Serial No. 908^

February 2, 1983 Testing ~ Program.

It also should be noted that on page 11-59, the only change requested by the NRC on not partial stroking during normal operation Valves MS-100 and MS-101, was to change code exception to Basis for Relief Request.

4.

. Alternative Valve Testing Proposed a)

The above technical and safety-related consid-erations, and potential for additional downtime, when partial stroking valves MS-100 and MS-101, result in no added safety benefits.

Toledo Edison requests permission to perform, in lieu of the partial stroke test during normal operation, a full stroke test at hot shutdown, as defined in Davis-Be'sse Technical Specification (Table 1-1, page 1-7).

Since ASME Section XI 1977 Edition through Summer 1978 Addenda, Article IWV-3412 only provides a definition for two (2) plant conditions, the full stroke testing will be performed when the plant is in hot shutdown condition (defined in the Davis-Besse Technical Specifications) at least once per 12 months or at a frequency not exceeding one test every three months.

5.

Other Verification on Valves MS-100 and MS-101 a)

TED proposes to introduce valve trends analysis on valves MS-100 and MS-101, which will allow monitoring of the valve's characteristic cach time the valve is full stroked.

By utilizing trends analysis during the full stroke testing, any abnormal behavior of the valves could be identified and appropriate action taken to correct any abnormalities.

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