ML20042F283

Forwards Rev 11 to Inservice Testing Program.

ML20042F283
Person / Time
Site:	Callaway
Issue date:	04/30/1990
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20042F284	List: ML20042F283 ML20042F286
References
ULNRC-2206, NUDOCS 9005080101
Download: ML20042F283 (7)

Text

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1901 Watst Street Post OHee % 149 St tres. M1s%n C3166

• 314 55426?a

)N Donald f. SchasR Etuc1 c 3p,11 30, 1,,o 5ent:t \'gt hes&nt m.,

'!3 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station PI-137 Washington, D.C. 20555 Gentlemen: ULNRC- 2206 CALLAWAY PLANT DOCKET NUMBER 50-403

_C&LLAWAY_f_ UMP AND _VALyE_INSERXLCE_

E TESTING PR_OGRAti This letter transmits Revision l'1 of the Callaway ,

Pump and Valve Inservice Testing (IST) Program. Attachment l 1 is a brief description of the changes, and Attachment 2 contains a copy of revised pages which should be inserted into the existing. program. NRC staff approval of this submittal is requested by September 1, 1990, so that some of these changes may be implemented during the Refuel IV outage.

Changes to the Callaway IST Program are subject to the fee provisions of 10CFR170. Therefore, Union Electric will accept charges incurred as a result of the NRC review.

If you have any questions concerning this submittnl, please contact me.

Very truly yourn, l

Donald F. Schnell 'l WEK/dvd Attachments .

9005080101 900430 PDR ADOCK 05000483 ' Ok( ,

P PDC k g

STATE OF MISSOURI-)

) SS CITY OF ST. LOUIS')

Donald F. Schnell, of lawful age, being first duly sworn upon oath says that he is Senior Vice President-Nuclear and an offic u of Union Electric Company; that he has read the foregoing document an*!

knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein. stated are true and correct to the best of his knowledge, information and belief.

By / / .

+

D'onald F.'Schnell Senior Vice President Nuclear SUBSCRJBED and sworn to before me this 3/)t4 day of (IMil , 1990.

I Ak JW .40 BARBAR/J. PF A(F [/ f N01ARY PUDLIC, STATE OF MISSOURI MY COMMISSION LXNRt3 APRIL 22,1993 ST. LOUIS COUNTY. , , , , ,

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l' cc Gerald Charnoff, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.

Washington, D.C. 20037 Dr. J. O. Cermak CFA, Inc.

4 Professional Drive (Suite 110)

Gaithersburg, MD 20879 R. C. Knop Chief,. Reactor Project Branch 1 U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office.

U.S. Nuclear Regulatory Commission RRM1 Steedman, Missouri 65077 Anthony T. Gody, Jr. (2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E21 11555 Rockville Pike Rockville, MD 20852 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102

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, Att:chment 1  :

Pag) 1 of 4 )

CHANCES TO CALLAVAY NUCLEAR PLANT INSERVICE TESTING PROGRAM j l

ITEM 1: CHANCE: Reduce maximum allowable stroke time for the following l valves. -

Old maximum New maximum  !

Valve (seconds) (seconds)  !

BB-HV-8026 10 $

BB-HV-8027 10 5 BB-HV-8001A 10 5 BB-HV-8001B 10 5 BB-HV-8002A 10 5 BB-HV-8002D 10 5 BB-PV-8702A 120 105 BB-PV-8702B 120 105 EG-TV-0029 50 25 EJ-HV-8701A 120 105 EJ-HV-8701B 120 105 EM-HV-8871 10 5 EM-HV-8964 10 5 EP-HV-8950A 10 'S EP-HV-8950B 10 5 EP-HV-8950c 10- 5 EP-HV-8950D 10 5 EP-HV-8950E 10 5-EP-HV-8950F 10 5 HB-HV-7126 10 5 HB-HV-7150 10 5' BASIS FOR CHANGE: Generic Letter 89-04 states that the limiting value of full-stroke time should be based on a valve reference or average stroke time-when the valve is known to operate properly. .The limiting 1 value should be a reasonable deviation from this reference stroke time. The Callaway Inservice-Testing Program limiting values of full stroke time were compared to the average or typical stroke time for each valve.: The referenced valve

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list includes all valves that are felt to have-unreasonably ~1arge limiting full stroke times.

The proposed new limiting stroke _ times are reasonable deviations'and consequently meet the dictation of Generic Letter.89-04..

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l Att chment 1 Page 2 of 4 ITEM 2 CHANGE: Add the following testing for valves AB-LV-0007, 0008, 0009, 0010t

a. full stroke time closed test, quarterly

b. fail safe testing, quarterly

c. position indication verification testing on a refueling frequency BASIS FOR CHANGEt A recent review of plant safety related systems and component operational requirements indicated that these valves are required to close in various accident analyses. This indicates that the specified testing is required to verify these active functions. _,

1 ITEM St CHANGEt Add full closed exercise testing for check valves BB-V-122, BB-V-152, BB-V-182, and BB-V-212. Add Relief Request BB-11 regarding these valves.

BASIS FOR CHANGE: This system recently underwent an extensive component operational requirement design review.

This review indicated the aforementioned check valves are required to close during a Reactor Coolant Pump Thermal Barrier rupture accident.

The cooling coil check valves, therefore, are to be tested c1.osed on a Reactor Refueling fre-quency. This testing cannot be performed at power since the cooling provided to the thermal barrier would be discontinued. Furthermore, due to the system design configuration, this test procedure requires isolation of all cooling water to the Reactor Coolant Pump bearings and motor, hence this procedure may only be performed during Refueling outages when these Pumps are not operating.

ITEM 4: CHANGE: Increase test frequency of BM-HV-1, BM-HV-2, BM-HV-3, and BM-HV-4 from a cold shutdown frequency to a quarterly test frequency. Delete Cold Shutdown Justification BM-1 regard-  !

ing these valves.

BASIS FOR CHANGE: Due to the operational requirements of these valves they may be full stroke time tested closed during power operations without causing serious plant perturbations. Plant operating experience and chemistry calculations have shown that these valves may remain closed for up to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> before chemistry conditions will force plant shutdown. Hence, testing in the closed direction may be performed during power operation.

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T Attscheent 1 Page 3'of 4 ITEM 5: CRANGE: Add the following testing for valves BN-HCV-8800A and -

BN-HCV-8800B:

a. full stroke time closed test, quarterly

b. fail safe test, quarterly

c. position indication verification testing on a refueling frequency..

BASIS FOR CHANGE: The safety classification of these valves has been changed'from passive to active based on present operational use of the valves. This indicates that the valves should be tested to verify this active function as stated above.

ITEM 6: CHANGE: Add the following testing for valves EJ-HCV-8825 EJ-HCV-8890A, and EJ-HCV-8890B

a. Full stroke closed test, quarterly

b. Fail Safe quarterly test c.. Position Indication Verification test on a refueling frequency BASIS FOR CHANGE: The operational classification for these valves has been changed to active from the previous passive classification. This change has occurred due to changing administrative controls involving the use of the valves. Consequently, this active function should be verified as stated above.

ITEM 7: CHANGE: Add the following testing ~for valves EM-HV-8823 EM-HV-8824. EM-HV-8881. EM-HV-8888, and EM-HV-8843:

a. Full stroke time closed test, quarterly

b. Fail Safe test, quarterly

c. Position Indication Verification test on a refueling frequency BASIS FOR CHANGE: The classification of these valves has been changed from passive to active due to operational requirements of the valves. The active function should be tested as stated above.

ITEM 8: CHANGE: Add the following tests for valves EP-HV-8808A and EP-HV-8808D. Add Cold Shutdown Justification EP-5.

a. Full stroke time closed test on Cold Shutdown frequency.

b.. Position Indication Verification test on a refueling frequency.

BASIS FOR CRANGE: A recent design review of.these valves indicates that they are to perform an active function of-going closed in some accident analyses scenarios.

This requires that the valves should be tested as specified in order to verify this function.

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Atttchment 1 Page 4 of 4 ITEM 9: CHANCE: Add the following testing for valve EP-HV-8880s

a. Full stroke time closed test, quarterly

b. Fail Safe quarterly test

c. Position Indication Verification test on a refueling frequency.

BASIS FOR CRANGE: The classification of this valve has changed from passive to active based on a change in the administrative control of operating this valve.

This change requires the above tests be performed in order to verify this active function.

ITEM 10: CHANGE: Add the following tests for valves LF-HV-105 and LF-HV-106:

a. Full stroke time closed test, quarterly

b. Position Indication Verification test on a refueling frequency.

BASIS FOR CRANGE: A safety system design review of this system revealed that the referenced valves are required to close under certain accident scenarios thereby making them active. This active function should be tested as stated above.

1 TEM 11: CHANGE: Revise Relief Request V04 to allow exemption from the requirements of IWV-3427.

BASIS FOR CHANGE: The dictation of IWV-3427 may be waived as specified in Generic Letter 89-04.

ITEM 12: CHANGE: Add relief request V07 to allow use of Acoustic monitoring techniques instead of full flow measurement for verifica-tion that the following check valves are full opent i BB-V-0001, 0022, 0040, 0059 BB-8949A, B, C, D EJ-8841A, B EM-V-0001, 0002, 0003, 0004 EP-V-0010, 0020, 0030, 0040 EP-8818A, B, C, D BASIS FOR CRANGE: ASME Section XI Subsection IWV-3522 indicates that confirmation of check valve disc movement may be made by a number of methods including "other positive means". Full flow measurement through individual check valves is recognized as a valid full open test. Non-intrusive methods of determining check valve position, however, have progressed sufficiently to warrant use in sur-veillance activities. In particular, acoustic monitoring, as demonstrated by the Nuclear Industry Check Valve Group (NIC) at. Utah State University, has been proven to work successfully. 1 I

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