ML20045E117
| ML20045E117 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/21/1993 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20045E118 | List: |
| References | |
| TAC-M84412, NUDOCS 9307010130 | |
| Download: ML20045E117 (21) | |
Text
,3
+
08 aver Valley Power Station
- 0. B I-Shippingport. PA 15077-0004 4
3 h
JOHN 'O. SIEBER (412) 393-5255.
Senior Vice Presdent and Fax (412) 643-8069 -
Yu$a"Mo.' r $ Ion June 21, 1993 U.
S. Nuclear Regulatory Commission Attn:
Document Control Desk-e
. Washington, DC 20555
Subject:
Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66.
BV-2 Docket No. 50-412, License No. NPF-73 Unit No. 1 and Unit No. 2 IST-Program; Remaining SER Issues (NRC Letter 12/30/92 - TAC M84412) i This letter provides information responding to issues detailed in-
- your December 30, 1992, letter (Serial No. BV-92-044) including:.
+
e Resolution of the May 6,
1991,.
Safety Evaluation Report (SER) anomalies, e
Resolution of the January 24, 1992,-Supplemental SER issues,-
e General comments on the IST Program, and e
Proposed Revision 1D (revised):to th'e'IST Program requiring.
NRC review and approval.
I
-We are also. submitting. anL informational. copy of-Issue : 2,,
Revision
-9
- of the Unit. No.-l'IST Program.; The enclosures'of this-letter address the'above items.
9 Enclosure 1
contains informationiassociated with the Unit'No.
1.
IST Program SER-and SSER.
There are-seven anomalies (f rom ' the ; SERs) L
- )
for which some action is required before~the NRC can consider our j
actions. complete.
' Details for NRC review-are contained in' Enclosure, 1.
Enclosure 2
provides responses
'to the general comments on the Unit No.
1.IST. Program providedin your December 30,.1992 letter and.
. includes a' commitment to. utilize the guidance provided by the NRC.for
.i
~
- the,use of. pump curves for-establishing acceptable. criteria when1 j
. evaluating pump. operational. readiness'.when tested.per ASME Section XI.
- 800%
g f
ee m c I
W U W of THE YEAR 9307010130 930621-f
,hDR.ADOCK'05000334
(%)i
~PDR
g Unit No. 1 IST Program; Remaining SER Issues
'l (NRC Letter 12/30/92 - TAC M84412) f Page 2 Enclosure 3
is a revised Proposed Revision ID to the Unit No. 1 IST Program.
Your December 30, 1992 letter provided the results of your review of our Proposed Revision 1D-submitted on August 18, 1992.
Therein, it was stated that our request for relief could not be approved as written, and additional guidance was provided for our use in preparing a
new relief request.
The enclosed Proposed Revision 1D-Revised addresses the use of pump curves for establishing acceptance criteria when evaluating pump operational readiness when the pump is tested per ASME Section XI.
The use of pump curves was discussed with the NRC IST reviewer on February 3, 1993, and guidance was provided regarding present testing.
All pump testing, with the exception of those identified in Proposed Revision 1D-Revised, will be conducted in accordance with ASME XI as described in our IST Program during the current refueling outage.
The reviewer indicated our revised relief request could be approved expeditiously if we followed the guidance in the December 30, 1992 NRC letter.
Approval of this relief request is requested by September 7, 1993.
Unit No. 2 will also commit to using the guidance provided by the NRC for the use of pump curves for establishing acceptance criteria when evaluating pump operational readiness when tested per ASME Section XI.
Unit No. 2 will utilize the guidance by the beginning of the fourth refueling outage based on receiving NRC approval of relief requests 7 and 8 by July 30, 1993.
Enclosure 4
is Issue 2,
Revision 9
of the Unit No. 1 IST Program.
We have determined that these IST Program changes do not require NRC approval prior to implementation.
This determination was made because all the changes are either:
e Editorial in nature.
In compliance with the 1983 Edition through Summer e
1983 Addenda of the ASME Section XI Code.
In compliance with the positions delineated in e of Generic Letter No. 89-04, " Guidance on Developing Acceptable Inservice Testing Programs."
If you have any questions regarding this submittal, please contact Mr. Steve Sovick at (412) 393-5211.
Sincerely,
\\
M_-
J.
D.
Sieber
'V Enclosures cc:
Mr.
L.
W.
Rossbach, Sr. Resident Inspector Mr.
T. T. Martin, NRC Region I Administrator Mr.
G.
E.
Edison, Project Manager Mr.
M.
L. Bowling (VEPCO)
DIE Response.to PRC Letter Dated December 30, 1992 (TAC No.-M84412)
ENCLOSURE 1 e
Resolution of issues contained in the May 6, 1991-SER and the January 24, 1992 SSER e - Table of Anomalics Figure 1 - Simplified Safety Injection Schematic e
I i
i i
i 1
i 1
ENCIDSURE 1 e
Resolution of Issues' Contained in the May 6, 1991 SER and the January 24, 1992 SSER On May 6, 1991, the NRC issued a Safety Evaluation addressing the second ten-year interval inservice testing program for Beaver Valley Unit No.
1.
That Safety Evaluatitn included the identification of 29 anomalies.
On January 24, 1992, the NRC issued a supplement to that Safety Evaluation which addressed the results of a
re-examination to the NRC's position related to certain relief requests discussed in the May.
6, 1991 Safety Evaluation.
On December 30,
- 1992, the NRC issued a Safety Evaluation which addressed our August 18, 1992 submittal.
That submittal provided additional information for NRC review _ to permit closeout of the remaining anomalies.
The December 50, 1992 Safety Evaluation has seven open anomalies which are addressed below.
Attachment 1
of -is a " Table of Anomalies" listing all of the actions taken to resolve the
- issues, including a
summary of the following actions pertaining to the seven open anomalies.
Anomalies 2 & 6:
The NRC noted that either permanent or temporary pressure gauges could be installed at existing test connections at the suction of the charging and quench spray pumps.
We will use temporary test gauges until permanent instrumentation can be installed.
The use of temporary test gauges was implemented for the inservice tests beginning with our ninth refueling outage (1R9).
Anomalies 13 & 14:
The NRC stated that the method used to verify the full-stroke open capability of the SI parallel branch line check valves should be revised.
The low head safety injection (LHSI) check _ 'alves to the cold legs were tested during 1R9 using the following test method'(see Figure 1) :
Portable ultrasonic flow meters were installed on each of the branch lines.
First one and then both LHSI pumps were aligned to provide flow to the cold legs.
Flows through each of the 3 branch lines were measured with both pumps running and compared to design accident flow requirements.
During 9R, sufficient flow was measured during the test to verify the full stroke open capability of the check valves in accordance with Position 1 of GL 89-04.
_.- (Continued)
'Page 2 Anomalies 13 & 14 (Continued):
As a
second
- check, a method similar to the Ft. Calhoun Nuclear Station method of testing the Accumulator discharge check valves was used.
The flows through each line and the differential pressures between the LHSI pumps at
[PI-1SI-900] and the RCS
- pressure, determined from pressurizer
- level, were calculated.
The line registance K'
was then calculated for each line where AP/Q.
The acceptance criteria for each line was K'
=
derived from the design of the system and accident flow rates.
The acceptance criteria for each line was met during 9R testing.
The portable ultrasonic flow. meters will be used for future testing of the SI parallel branch line check valves.
Anomalv 15:
The NRC stated that the method used to verify the full-stroke open capability of the SI accumulator discharge check valves should be revised.
The SI accumulator discharge check valves were tested during 1R9 using a
method similar to the test used at the Ft. Calhoun Nuclear Station.
The test method measured a flow coefficient value (C )
during a blowdown at reduced accumulator pressure in y
conjunction with a non-intrusive test.
The NRC approved the use of this method for 1R9 in the letter dated February 8, 1993.
Anomalv 26:
The NRC stated that the control room emergency air bottle outlet trip isolation valves should be monitored for degradation during their quarterly test.
-i We agree to time the stroke of these valves in one of the two tests that stroke the valves (2 valves in 1/2 OST-44A.11 and 3 valves in 1/2 OST-44A.12).
The stroke will be timed locally by measuring the observed time between the open and closed indicators on the valve stems.
This relief request (VRR-37) has been deleted in Rev. 9 of the IST Program.
Anomalv 27:
The NRC requested that we investigate methods to verify full and partial-stroke exercising for the check valves in the~ IST
- Program, such as installation of flow instrumentation or utilization of non-intrusive techniques.
' (Continued)
Page.3 Anomalv 27 (Continued):
During the review of the testing methods used at_BVPS, the use of several different testing techniques, including the addition of i
flow instrumentation and non-intrusive equipment was considered for the valves addressed in the Safety Evaluation.
Portable flow meters will be used for the SI branch line test and-a non-intrusive method will be used for the accumulator discharge check valve test.
We will evaluate the results obtained during 1R9 to determine the effectiveness of these methods.
A review of other check valve test methods for the possibility of improving the quality of the tests, will be ongoing.
Whenever the check valve test procedures are
- revised, the use of non-intrusive diagnostic techniques will be evaluated.
This initial review will be complete by the next 10-year interval.
TABLE OF ANOMALIES SAFETY EVALUATION BVPS-1 INSERVICE TESTING PROGRAM Anomaly '
. Description of Anomaly (May 6,1991 SE)
Status of DLC's Actions Outstanding Actions
- 1. PRR-1 The licensee requested to measure vibration DLC had revised Relief Request The actions requested in the velocity instead of vibration displacement PRR-1 to specify that vibration anomaly are complete. No for all pumps in the IST Program except measurements are to be performed in further action is required.
residual heat removal and low head safety accordance wirh the requiremerts of COMPLETE injection pumps. - The licensee requested to OM-6. The acceptance criteria of discontinue annual bearing temperature OM-6 i-included in the relief measurements on these same pumps. The request.
proposal to monitor pump vibration ve' y
in lieu of displacement and annual 7 at temperature measurements was dr rmim. > be an acceptable alternative with t' that the licensee comply wim au dw vibration measurement requirements of ASME Operations and Maintenance Standards Part 6, inservice Testing of Pumps in Light-Water
_g Reactor Power Plants..
- 2. PRR-2 The licensee requested relief fro.a measuring DLC verified that the inlet pres-Interim relief was granted for
- 6. PRR-2 inlet pressure for the charging and quench sure calculations meet the Code one year or until the next spray pumps and proposed to calculate inlet requirements. The charging and refueling outage, whichever NOTE: PRR-2 pressure based on the height of fluid above quench spray pumps will be deleted was longer. This action is to included the pump suction. The proposed method is from this relief request in Rev. 9, be resolved during refueling several pumps acceptable provided the accuracy requirements to be issued by 9R. Temporary outage 9R. The licensee will 4
discussed in of the Code are met. However, the reviewer gauges will be used until permanent install gauges or use g
several noted that Piping and Instrument Diagrams gauges can be installed.
temporary gauges. The use of
[.
anomalies.
indicate test connections where instrumentation temporary gauges was incorporated g
could be installed.. Interim relief was granted prior to startup from 9R.
rt to allow time for an investigation by DLC.
P 1
Ar.c,-ly.
Description of Anomaly (ILty 6,1991 SE) s Status of DLC's Actions -
l Outstanditg Actions !
- 3. PRR-2 The licensee requested relief from measuring DLC verified that the inlet pressure The concerns of this anomaly
- 5. PRR-2 inlet pressure for the boric acid, safety calculations are within the Code have been addressed. No
- 7. PPR-2 injection, inside and outside recirculation required accuracy.
further action is required.
- 8. PRR-2 spray and river water pumps and proposed COMPLETE
- 10. PRR-2 to calculate inlet pressure based on the heigl of fluid above the pump suction.' The proposed method is acceptable provided the accuracy requirements of the Code are met.
- 4. PRR-3 '.
Relief from measuring flow rate for the boric DLC verified that the flow rate The concerns of this anomaly acid pumps was requested with a proposal to calculations are within Code have been addressed. No calculate flow during refueling outages.
accuracy requirements. Separate further action is required.
Relief was granted with the provision that vibration reference values will be COMPLETE the licensee ensure that calculations utilized for each test flow performed meet the Code accuracy requirements condition in the implementing for flow measurement. Additionally, the procedures.
}
licensee was to establish two sets of reference data for vibration because the flow path utilized during refueling outages is y
e different than the one utilized during quarterly testing.
- 9. PRR-8 Relief was requested from measuring flow rate The quarterly pump tests include Reference values have been quarterly for auxiliary feedwater (AFW) measurement of both differentia! -
established for each different pumps, and alternatively, measuring flow rate pressure and vibration with test configuration. The on a refueling outage frequency. Relief was comparison to reference values.
concerns of the anomaly have granted with the provision that the licensee -
The pumps are also tested during been addressed. The vibration investigate several discrepancies noted by cold shutdowns when the full-flow reference values are subject N
the reviewers: (1) testing at cold shutdowns testing of the check valves is to NRC inspection. No further E
~
was not discussed, (2) cold shutdown performed. The IST Program was action is require <L justification 25 indicated that the AFW pump '
revised to reference the cold shut- '
COMPLETE discharge check valves are full stroLed open -
down testing for these pumps.
during cold shutdown, (3) PRR-8 is not Separate "bration reference values onsistent with the pump testing outline, and are utilized for each flow point..
E c
(4) vibration reference values for both test -
{
configurations should be established.
A i
- Anomaly -
Description of Anomaly (May 6,1991 SE)
Status of DLC's Actions Outstanding Actions-
- 11. PRR-10 The licensee requested relief from measuring -
DLC verified that the flow rate The concerns of this anomaly llow rate for the diesel fuel oil transfer calculations are within the Code have been addressed. No pumps and proposed to calculate flow rate required accuracy.
further action is required, based on the change in day tank level. The COMPLETE proposed method is acceptable provided the accuracy requirements of the Code are met.
- 12. VRR-7 The licensee proposed to assign a maximum DLC evaluated the allowable leakage The concerns of this anomaly permissible leakage rate to the associated rates for penetrations where have been addressed. No penetration and not individual valves, for individual leakage rates cannot be further action is required.
chemical and volume control system valves obtained. The maximum allowable leak COMPLETE TV-CH-200A, -200B, and -200C, as requirei by rate assigned to the entire penetra-the Code. Relief was granted provided the tion is the vslue normally assigned limiting leak rate for the penetration is to the smallest valve in the group.
conserva6ve considering the number and size la the subject penetration, the valves of the van s in the group and does not allow are 2-inch valves. The individual excessive leakage through any particular allowable lear rate for one 2-inch valve in the group to go uncorrected.
valve is 160 scfd; therefore, the y
allowable leak rate for this i
penetration is 160 scfd.
13 VRR-16 The licensee requested relief from exercising This relief request was further DLC has submitted the revised 14 VRR-18 safety injection cold leg check valves addressed in an NRC SE dated January.
test plan to the NRC for review.
S1-10/11/12 and S1-23/24/25 quarterly and 24,1992, which stated that " based by copy of this letter. The proposed to exercise these valves during on the uncertainties of the proposed results of this test during 9R refueling outages. Relief was granted based alternative test methods in verifying -
were satisfactory, verifying the on the impracticality of Code compliance due full-stroke opening of the subject full stroke opening.:apability
- g to the lack of flow instrumentation in the check valves, the licensee should of these check valves.
7 lines. However, it was unclear to the revise the testing to meet either COMPLETE
[.
reviewer how a full-stroke open of these Position 1 or Position 2 of GL R9-04
[
valves could be verified during refueling
... by the next refueling outage."
it outages.
The testing method will be revised P
to utilize portable ultrasonic flow 7
meters and the differential pressure g
across the line. Non-intrusive test M-methads will also be evaluated.
H
~
F h
Anomaly
. Description of Anomaly (Miy 6,1991 SE) -
' Status of DLC's Actions
- Outstanding Actions'
- 15. VRR-20 The licensee requested relief from exercising This relief request was further The NRC has ' pproved the use a
accumulator discharge check valves SI-48/49/50 addressed in an NRC SE dated January of the proposed method for 9R. ~
and SI-51/52/53 quarterly and proposed to 24, 1992, which stated that
- based Final approval is pending the exercise these valves during refueling on the uncertainties of the proposed completion of the review of outages. Relief was granted based on the alternative test methods in verifying this method by the Oak Ridge impracticality of Code compliance due to the full-stroke opening of the subject Laboratories.
lack of flow instrumentation in the lines, check valves, the licensee should flowever, it was unclear to the reviewer how a revise the testing to meet either full-stroke open of these valves could be Position 1 or Position 2 of GL 89-04 verified during refueling outages.
... by the next refueling outage.'
The test method will be revised to measure a Cy value during a blowdown at reduced accumulator pressure in conjunction with a non-intrusive test similar to the method used at Ft. Calhoun Nuclear Station.
- 16. VRR-21 The licensee requested relief from quarterly DLC has determined that ihese valves The concern of this anomaly exercising safety injection check valves SI-can be part-stroke exercised during has been addressed. No further
_3 i
83/84 and proposed to full-stroke exercise cold shutdown conditions. The action is required.
these valves during refueling outages. Based relief request has been revised COMPLETE on drawings provided, a partial-stroke (Revision IC) to include this exercise of these valves could be performed -
provision.
during cold shutdown conditions.- Relief was granted with the provision that the licensee develop a method to part-stroke these valves during cold shutdown C.
- t:
E-1
. _ _ =
Anomaly '
Description of Anomaly (M:y 6,1991 SE)
Status of DLC's Actions Outstanding Actions.
- 17. VRR-22 The licensee requested relief from quarterly DLC has determined that valve SI-95 The concerns of the provision exercising boron injection and safety injection can be part-stroke exercised during of the granted relief have check valves SI-94/95 and proposed to full-cold shutdown conditions, and is now been addressed by the additional stroke exercise these valves during refueling included in VRR-21. Valve SI-94 justification included in VRR-22.
outages.. Based on drawings provided, a partial-cannot be part-stroke exercised during Therefore, the relief previously stroke exercise of these valves could be cold shutdown. Relief Request VRR-22 granted remains acceptable for performed during cold shutdown conditions.
has been revised (Revision IC) to full-stroke exercising valve Relief was granted with the provision that the address boron injection tank check SI-94 during refueling outages.
licesnee develop a method to part-stroke these valve SI-94 and includes justification No further actioa is required.
valves during cold shutdown.
of the impracticality of part-stroke COMPLETE exercising during cold shutdown as follows; 'Part-stroke testing during CSD is not possible because the only flow path available is through the BIT. Stroking the BIT outlet isola-tion valves could result in borated, oxygenated water from the BIT entering the downstream piping. With no means m
to flush out the downstream lines, t
stagnant conditions develop upon valve closure. The ability to Ilush out the downstream piping to minimize the probability of intergranular stress corrosion cracking formation is only possible during refueling outages in conjunction with the Si full flow test."
N
- 18. VRR The licensee requested relief from quarterly Relief request VRR-23 has been The concerns of this anomaly N
exercising boron injection tank inlets, MOV-deleted from the IST Program. Cold have been addressed. No f
SI-867A/B, and proposed to full-stroke Shutdown Justification No. 32 was further action is required.
3 exercise these valves during refueling outages.
created for these valves indicating -
COMPLETE Relief was denied based on inadequate that testing is performed during justification of the impracticality of cold shutdowns.
xercising these valves during cold shutdowns e
when charging pump discharge pressure is s
ignificantly lower.
s
+
' Anomaly -
Description of Anonuly (Msy 1991 SE)
Status of DLC's Actions Outstanding Actions
- 19. VRR-13 The licensee proposed using disassembly and DLC has revised VRR-13 to include the The concerns of the provision inspection to exercise safety injection basis for the impracticality of part-of the granted relief have check valves SI-1/2. Relief was granted stroke exercising these valves been addressed by the additional with the provision that the licensee address following reassembly. The only flow justification included in VRR-13.
whether a part-stroke exercise is practical path available to test these valves Therefore, the relief previously following reassembly, in accordance with the is to fill the containment sump with granted remains acceptable for guidance in the Minutes of the Public water and start the low head safety valves SI-1/2. No further action Meetings on GL 89-04.
injection pumps. This would result is required.
in contaminated and dirty water being COMPLETE introduced into the refueling water storage tank and the reactor coolant system.
20 VRR The licensee proposed using disassembly and DLC has revised VRR-25 to include the The concerns of the provision inspection to exercise safety injection basis for the impracticality of part-of the granted relief have -
check valves RS-158 and RS-160. Relief was stroke exercising these valves been addressed by the additional granted with the provision that the licensee following reassembly. The only flow justification included in VRR-25.
address whether a part-stroke exercise is path available to test these valves Therefore, the relief previously practical following reassembly, in accordance is to fill the outside recirculation granted remains acceptable for a
a wtih the guidance in the Minutes of the Public spray pump casing with water and valves RS-158 and RS-160 Meetings on GL 89-04.
start the pump.. The manual isolation Because the valves cannot be valves would then be opened and the part-stroke exercised following test would verify flow through the reassembly, the licensee should check valves, using an ultrasonic ensure that the maintenance flow meter, to the charging system.
procedures include provisions Otherwise, the volume of water used for proper disk orientation. No to test the outside RS pumps is insuf-further action is required. Also ficient to stroke the check valves, DLC is investigating deleting g-even if the flow is directed to the these valves from the IST Program.
g suction of the HHSI pumps.- The part-COMPLETE j$
stroke would introduce water with entrained air into tia charging / reactor rt coolant systems, resulting in chem-P istry problems in the primary coolant,-
and is, therefore impractical.
1
~ Anomaly -
Description of Anomaly (Mxy 6.1991 SE)
. Status ef DLC's Actions
.Outstading Actions;
- 21. VRR-27 Interim relief was granted for one year or DLC has submitted a revised relief Relief was granted in the SE until the next refueling outage, whichever is request (Revision IC). These boundary dated 12/26/92 pursuant to longer, to assign a maximum leak rate to an valves cannot be individually leak 10 CFR 50.55a (f)(6)(i). No entire penetration barrier instead of assigning rate tested. The boundary downstream further action is required.
individual valve leak rates to component valve,110F1, is a potentially open COMPLETE cooling water valves TV-CC-Il0FI/110F2 as check valve leading to the circulating required by the Code. It appeared that for water system. Therefore, the river the particular penetration, individual leak water system downstream of 110F1 can-rates could be assigned and measured.
not be isolated to provide an accurate leakage rate for 110F2.
- 22. VRR-30 The licensee requested relief from quarterly DLC is incorporating a partial-GL 89-01, Position 2, approved eercising main steam check valves MS-80/81/82 stroke exercise following reassembly.
the use of a disassembly and and proposed to disassemble and inspect these The relief request has been revised inspection program for check valves during refueling outages on a rotatmg to describe the impracticality of valves as 'a positive means of schedule. Relief was granted with the performing closure verification by determining that a valve's disk provision that a partial-stroke exercise means other than by disassembly will full-stroke exercise open i
following reassembly be performed, if practical.
and inspection.
or of verifying closure Interim relief was granted to allow a period capability, as permitted by 4
I for determination of a method to verify IWV-3522.* Therefore, this closure.
relief request is approved per GL 89-04, with the provision that the licensee implements the disassembly and inspection program in accordance with the guidance delineated in Position 2. -
COMPLETE St
- 23. VRR-32 The licensee requested relief from quarterly A part-stroke exercise quarterly has The concerns of this anomaly tc' exercising river water check valves RW-110/111 -
been incorporated into VRR-32. The have been addressed. No N@
112/113 and proposed to disassemble and inspect ;
intent is to disassemble and inspect further action is required.
these valves during refueling outages on a one valve each refueling outage on a COMPLETE rotating schedule. Relief was granted with the rotating schedule such that each N
provision that a partial-stroke exercise valve is inspected at least once.
following reassembly be performed, if practical.
every 5 years. The relief request g
The reviewer indicated that it was unclear what has been revised to more clearly
- once every 5 years
- meant for the schedule of.
stipulate this schedule.
disassembly and inspection, s
Anomaly '
Description of Anomaly (Miy 6,1991 SE) "
Status of DLC's Actions -
Outstrnding Actions -
- 24. VRR-33 Relief from quarterly exercising river water DLC has removed the internals of these No further action is required.
check valves RW-135/136 was requested with a check valves. Therefore, VRR-33 is COMPLETE proposal to full-stroke these valves during -
no longer required. The valves are refueling outages. Interim relief was granted no longer in the IST Program. The to allow the licensee a period to determine revised program submitted 9/25/92 if exercising can be performed in accordance deleted the valves and this relief with the Code required frequency.
request.
- 25. VRR-34 The licensee requested relief from quarterly DLC has removed the internals of these No further action is required.
exercising check valves RW-197/198 and proposed check valves. Therefore, VRR-34 is COMPLETE to disassemble and inspect these valves during no longer required. The valves are refueling outages on a rotating schedule.
no longer required to be exercised Relief was granted with the provision that a.
and are no longer in the IST Program.
partial-stroke exercise following reassembly The revised program submitted 9/25/92 be performed, if practical.
deleted the valves and this relief request.
~
- 26. VRR-37 Relief from quarterly stroking and timing DLC revised the relief request to These valves will be monitored control room emergency air bottle outlet trip stipulate that the valves will be for degradation by timing the isolation valves was requested with a proposal stroked quarterly. The current stroke. This relief request to stroke these valves once every 18 months, revision of VRR-37 relates only to was deleted in Rev. 9, issued but not measure stroke times. Interim relief not measuring stroke time. DLC has on April 1,1993.
was granted for a period of one year or until re-reviewed the test method and has.
COMPLETE the next refueling outage, whichever is longer, developed a method of timing the The licensee was requested to investigate stroke of these valves. The relief nonintrusive methods to monitor for valve request will be deleted in Rev. 9 degradation.
of the IST Program, to be issued
- p rt by 9R.
g 27cN/A The licensee was requested to investigate -
During the review of the testing DLC will evaluate the use of methods to verify full and partial stroke methods used at BVPS, the use of non-intrusive testing techniques rt exercising for various valves, such as several different testing techniques, for verification of full and P
installation of flow instrumentation or including the addition of flow part stroke exercising check g
utilization of nonintrusive techniques.
instrumentation and non-intrusive '
valves as an on going process, y
equipment, was considered for the to be complete by the next f5 valves addressed in the SE.
10-year update.
w
N
. Anomaly '
- Description of Anomaly (M:y 6,1991 SE) -
Status of DLC's Actions ;
Outstanding Actions
- 28. VRR-15 Relief was requested from quarterly exercising DLC reviewed the partial-stroke The concerns of this anomaly low head safety injection pump discharge check exercising method. The valves had have been addressed by the valves SI-6/7 in accordance with IWV-3522 been considered to be part-stroke revision to VRR-15. The relief with a proposal to perform partial-stroke exercised by recording the pressure previously granted remains exercising quarterly sad full-stroke exercising change in a dead leg of pipe down-effective for the revised relief during refueling outages. Provisional relief stream of the check valves before request to allow full-stroke was granted because information on the method and after pump start. It was deter-exercising with accident flow of partial-stroke exercising was not included mmed that this method does not during refueling outages.- No in the relief request.
provide a true part-stroke of these further action is required.
valves. Relief Request VRR-15 was -
COMPLETE revised to more correctly indicate that these valses are exercised closed quarterly and full-stroke exercised open at refueling outages.
- 29. VRR-19 Relief was granted from the quarterly DLC has revised VRR-19 to indicate The concerns of this anomaly exercising frequency for check valve SI-27, that a part-stroke exercise will be have been addressed by the i
high head safety injection / charging pump performed quarterly when system revision of VRR-19. No refueling water storage tank suction valve, configuration permits, that a part-further action is required.
e s
with a proposal to partial-stroke the valve stroke exercise will be performed COMPLETE quarterly and full-stroke exercise the valve on a cold shutdown frequency, and during refueling outages, with the provision that a full-stroke exercise will be that a partial-stroke exercise be performed performed during refueling outages.
when shutting down from power operation to cold shutdown in addition to the proposed testing.
N c.
!=
En H
E-
e Simplified Safety injection Schematic-FI 83 933 85 20
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Fl g L *a 84 932 87 22 g
X.
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5 O3 X_ o*
- g 960 86
~21
' " ' '{
2 g
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DLC Response to NRC Letter Dated December 30,.1992 (TAC No. M84412)
ENCLOSURE 2 e
Responses to General NRC Comments on the Unit No 1-IST Program
ENCLOSURE 2 e
Responses to General NRC Comments on the Unit No. 1 IST Program Comment:
($
5.0)
If the licensee determines that for certain pumps, testing in accordance with the Code is impractical, specific relief should be requested describing' the-impracticalities of performing -testing at a reference value of flow or differential pressure and the related burden.
In the relief request, the licensee should discuss the following guidance related to using pump curves:
(1)
Curves are developed, or manufacturer's pump curves are validated, when the pumps are known to be operating acceptably.
(2)
The reference points used to develop or validate the curve are measured using instruments at least as accurate as required by the Code.
(3)
Curves are based on an adequate number of points, with a minimum of five.
(4)
Points are beyond the " flat" portion (low flow rates) of the curves in a
range which includes or is as close as practicable to design basis flow rates.
the curves 'oes-not conflict-(5)
Acceptance criteria based on d
with Technical Specifications or Facility Safety Analysis Report operability criteria, for flow rate and differential pressure, for the affected pumps.
(6)
If vibration levels vary significantly over the range of pump conditions, a
method for assigning appropriate vibration acceptance criteria should be developed for-regions of the pump curve.
(7)
When the reference curve may have been affected-by repair, replacement, or routine service, a new reference curve shall-be determined or the previous curve revalidated by: an inservice test.
Response
We will-include these guidelines in Section I,
" Pump Testing Requirements" of the Unit No.
1 and Unit No. 2 IST Programs rather than in each individual pump relief request dealing with pump curves.
These guidelines will be incorporated into_the next IST Program revisions _ following NRC approval of our relief requests regarding use of pump curves.
i 4
Page 2 Comment:
(1 6.1) When to Declare a Valve Inoperable.
The valve inservice testing program includes an apparent inconsistency in Section IV.A.2.e.,
Category A and B valves, and IV.B.S.,
Category C check valves.
Section IV.A.2 states that "If a
valve fails to exhibit the required change of valve stem or disk position or exceeds its specified ASME limiting value of full-stroke
- time, the valve shall be declared inoperable immediately and an evaluation of the valve's condition with respect to system operability and technical specifications shall be made..."
Section IV.A.2.e contradicts this general statement by stating that "If the valve is not covered by any technical specifications and the condition of the valve cannot be corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, then the valve shall be declared inoperable per ASME."
A similar discrepancy exists in the check valve section t
for a failure to exhibit the required change of disk position.
The position stated in the general sections for declaring a valve inoperable immediately upon demonstration of exceeding its stroke
- time, or failing to exhibit the required change of disk position for a
check
- valve, is correct and is in accordance with the guidance given in GL 89-04, Position 8,
" Starting Point for Time Period in TS ACTION Statements."
The guidance states that "it is the staff's position that as soon as the data is recognized as being within the Required Action Range for pumps or exceeding the limiting value of full-stroke time for valves, the associated component must be declared inoperable and the TS ACTION time must be started."
However, this statement was not meant to imply that valves which are not covered by TS are np_t required to be declared inoperable when test data exceeds established acceptance limits of Section XI.
It appears that the licensee has differentiated between valves covered by technical specifications and valves not covered by technical specifications.
There should be no distinction other than that the inoperable condition of certain valves would not require entry into a'
TS ACTION statement.
The statements included the following action for valves not covered by TS which fail to meet the inservice testing acceptance criteria:
(1)
Declare valve inoperable immediately.
(2)
If not covered by TS and condition cannot be corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, declare the valve inoperable.
As
- written, the valve would be declared inoperable twice.
The discrepancy should be corrected.
\\ (Continued)
Page 3 j
1
'I
Response
1 The
" Valve Testing Requirements" section of the BV-1.IST Program will-be -revised as recommended to delete the statements, "If.the
)
valve is not covered by any technical specifications and the:
condition of the valve cannot be corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, then the valve shall be declared inoperable per ASME."
This change has been corrected in Rev. 9 of the IST' Program.
Comment:
($ 6.2) Including Procedure Numbers in Relief Requests.
($ 6.3) Recommendations Regarding Information to Include in Relief Requests.
($ 6.4) Program Items These paragraphs include the identification of typographical errors and general recommendations for improving the level of detail in the IST Program and in relief requests.
Response
The minor editorial changes noted have been corrected in Rev. 9 of the IST Program.
The other recommendations will be further evaluated.
Changes to the IST Program will be accomplished as revisions are developed (i.e.,
incorporating into relief requesta as new ones are written; incorporating into program changes and into all relief requests at the next 10-year interval updates for-both Units).
>