ML20045G610
| ML20045G610 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/06/1993 |
| From: | Horng R NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NSD930791, NUDOCS 9307140194 | |
| Download: ML20045G610 (6) | |
Text
.,
s GENERAL OFFICE.
P.O. BOX 499 COLUMBUS, NEBRASKA G8602-0499 Nebraska Public Power District
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- NSD930791 July 6,1993 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555
Subject:
Inservice Testing Program Relief Requests Cooper Nuclear Station.
NRC Docket No. 50-298, License No. DPR-46
References:
1.
Letter NSD920965, from G. R. Horn to NRC, dated September 14, 1992, " Inservice Test Program Addenda, Cooper Nuclear Station, NRC Docket No. 50-298, DPR-46" J
i 2.
Letter from NRC to G. R. Horn, dated April 7, 1993,." Safety Evaluation of the October 15, 1991, September 14, 1992, and February 15, 1993, Relief Requests Related to the ~ Inservice Testing Program for Pumps and Valves for. Cooper Nuclear Station (TAC No M84734)"
3.
Letter NSD930690 from G. R. Horn to NRC, dated June 7,1993..
" Status of Issues Related to Unit Startup" Gentlemen:
In Reference 1, Nebrask.a Public Power District (the District) submitted an addenda to the Cooper Nuclear Station (CNS) Inservice Test.(IST) Program, F
which included revised relief requests RV-28 and RV-45.
Reference 2 provided the District with the NRC Safety Evaluation of these relief requests. The safety evaluation concluded that additional information or basis for relief were required before approval could be granted for Relief Requests RV-28 and-RV-45.
The District provides the following clarification to specific sections of the.
safety evaluation that indicated additional information or basis for relief was needed for the two relief requests in order for the NRC to complete their review.
Response to 3.0 of Safety Evaluation (RV-28)
Relief Request RV-28 is withdrawn. Research has concluded that the subj ect check valves may be exercised during cold shutdowns when the drywell is
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de-inerted.
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Testing during cold shutdowns is allowable via'ASME Section XI, IWV-3522, 1980 Edition, Winter 1981 Addenda. Therefore, Cooper Nuclear Station (CNS) is in compliance with ASME Section XI regarding testing of the. subject check valves.
However, since there will be instances when the plant goes to a cold shutdown' condition for repairs without de-inerting the drywell, a relief request for not testing during a cold shutdown.inerted condition is necessary, J
1 Accordingly, the District is submitting with this letter a new Relief Request,.
RV-58, for cold shutdown testing for your review and approval.
Also attached for information concerning this relief request, is Technical Justification TJV-15.
Relief Request RV-58 and Technical Justification TJV-15 will be included in the next IST Program addendum.
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a U.S. Nuclear Regulatory Commission July 6, 1993 Page 2 of 2 Response to 5.0 of Safety Evaluation (RV-45)
Revised Relief Request RV-45 deleted two valves, RCIC MO-17 and HPCI-M0;57, and changed valve identifiers from RCIC AO-22.to RCIC-CV-260V and-HPCI-AO-18 i
to HPCI-CV-29CV.
Therefore, RCIC-CV-26CV and HPCI-CV-29CV are not new valves.
Relief Request RV-45 does not contain Event V pressure isolation valves U
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(PIVs).
By letter dated March 17, 1980, the District stated that no Event V arrangements existed at CNS.
The District's. response of September 26,'1989, i
1 to Generic. Letter 89-04, and a follow-up. letter dated Marchil4, 1991, which provided additional information regarding-GL 89 04, stated that 1) CNS Technical Specifications do not list or designate any PIVs, and 2) no Event V PIV configurations were identified at CNS.
The letters concluded that Position 4 of GL 89-04 does not address a situation that is applicable to CNS.
Therefore, the designation on page 80 of the IST. Program indicating RV-45'is pre-approved by GL 89-04 is correct.
It should be noted however, that the District has recently committed to individually leak test valves designated as pressure isolation valves (PIVs) as part of augmented testing.
This is discussed further in Reference 3.
The District has also revised Relief Request RV-45 as a result of recent changes to the District-testing methodology.
Some of'the penetrations / valves were deleted from the relief request and'other_ changes were made to include information regarding valve testing configuration, individual valve' testing impracticality, and how leak rate acceptance criteria is applied.. Revised i
Relief Request RV-45 is attached for your review.
Relief Request RV-45 will be included in the next IST Program addendum.
Should you have any questions or require additional information regarding these matters, please contact J. R. Flaherty, CNS Engineering Manager.
Sincerely, l
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'.R lorn hac1 ar Power Group Manager CRH: RAS:sa Attachments cc:
NRC Regional Office Region IV Arlington, Texas NRC Resident Inspector Cooper Nuclear Station 3
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i RELIEF REQUEST RV-58 VALVE:
MS-CV-20CV MS-CV 24CV MS-CV-28CV-MS CV-32CV MS-CV-21CV MS-CV-25CV MS CV-29CV MS-CV-33CV MS-CV-22CV MS-CV-26CV MS-CV 30CV MS-CV-34CV
,1 MS-CV-23CV MS-CV-27CV MS-CV-31CV MS-CV-35CV j
CLASS:
3 FUNCTION:
Check valves required to open for vacuum relief of the Main Steam Relief lines to the suppression pool.
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REQUIRED
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TEST:
Exercise each quarter or when in. cold shutdown in accordance with-
'IWV 3522.
BASIS FOR RELIEF:
For the reasons stated in Technical Justification TJV-15, these' valves can only be exercised during cold shutdown when the drywell j
is de-inerted.
These valves are located in the drywell and.
therefore, are only accessible when the plant is. shutdown and the drywell de-inerted The drywell is not normally de-inerted when reaching the cold shutdown condition and is undesirable due to the cost and amount of time required.
Except for refueling outages, cold shutdowns are usually unnecessary and if a shutdown occurs, down time.is kept to a minimum.
De-inerting containment for check valve testing is considered to be an unreasonable burden.
ALTERNATIVE TEST:
These valves will be mechanically exercised during cold shutdown periods when the drywell is de-inerted.
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TECHNICAL JUSTIFICATION TJV-15 VALVE:
MS-CV-20CV MS-CV-24CV MS-CV-28CV MS-CV-32CV MS CV-21CV MS-CV-25CV MS-CV-29CV MS-CV-33CV MS-CV-22CV MS-CV-26CV MS-CV-30CV MS-CV-34CV MS-CV-23CV MS-CV-27CV MS CV-31CV MS-CV-35CV CLASS:
3 FUNCTION:
Check valves required to open for vacuum relief'of the Main Steam Relief 1ines to the suppression pool.
BASIS FOR TECHNICAL JUSTIFIC-ATION:
These vacuum breaker check valves are located inside containment and are not equipped with actuators or position indicators.
Manual exercising requires drywell access.
The drywell-is not accessible during normal station operations and therefore the valves cannot be full-stroked or partial-stroke exercised during normal station operations.
ALTERNATIVE TEST:
Each valve will be mechanically exercised during cold shutdown, in accordance with IWV-3522, when the drywell is de-inerted (Relief' Request RV-58).
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RELIEF REQUEST RV-45 VALVE:
Penetration Valves
'l X-7A MS-A0V-A080A, MS-A0V-A086A X-7B MS-A0V-A080B, MS-A0V-A086B X-7C MS-A0V-A080C, MS-A0V-A086C X-7D MS-A0V-A080D, MS-A0V-A086D-X-8 MS-MOV-M074, MS-MOV M077
-X-9A RF-CV-15CV, RCIC CV-26CV, RWCU CV-15CV
'l X-9B RF-CV-13CV, HPCI-CV-29CV
.X-10 RCIC-MOV-M015, RCIC-MOV-M016 X-11 HPCI-MOV-M015, HPCI-MOV-M016 X-16A CS-MOV-M011A, CS-MOV-M012A X-16B CS-MOV-M011B, CS-MOV-M012B X 25 PC-MOV-232MV, PC-A0V-238AV' l
X-25 PC-MOV-1305MV, PC-MOV-1306MV X-26 PC-MOV-231MV, PC-A0V-246AV, PC-MOV-306MV, PC-MOV-1310MV' X-39A RHR-MOV-M026A, RHR-MOV-M031A X-39B RHR-MOV-M026B,.RHR-MOV-M031B
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.X-39B PC-MOV-1311MV, PC-MOV-1312MV X-41 RR-A0V-740AV, RR-A0V-741AV X-205 PC-MOV-233MV, PC-A0V-237AV X-205 PC-A0V-243AV, PC-CV-13CV X-205 PC-A0V-244AV, PC-CV-14CV X-205 PC-MOV-1303MV, PC-MOV-1304MV X-210A RCIC-MOV M027, RCIC-CV-13CV l
X-210A RHR-MOV-M016A, RHR-CV-10CV, RHR-CV-12CV
'l X-210B HPCI-MOV-M025 HPCI-CV-17CV X-210B RHR-MOV-M016B, RHR-CV-11CV, RHR-CV-13CV X-210A, 211A RHR-MOV-M034A, RHR-MOV-M038A, i
RHR-MOV-M039A X-210B, 211B RHR-MOV-M034B, RHR-MOV-M038B, RHR-MOV-M039B X-211B PC-MOV-1301MV, PC-MOV-1302MV I
'X-212 RCIC-CV-15CV, RCIC-V-37 1
X 214 HPCI-CV-15CV, HPCI-V-44 X 214 RHR-MOV-M0166A, RHR-MOV-M0167A X-214 RHR-MOV-M0166B, RHR-MOV-M0167B X-214 HPCI-A0V-A070, HPCI-A0V-A071 X 220 PC-MOV-230MV, PC-A0V-245AV, PC-MOV-305MV, PC-MOV-1308MV X-221 RCIC-CV-12CV, RCIC-V-42 X-222 HPCI-CV-16CV, HPCI-V-50 CLASS:
1, 2 FUNCTION:
Primary Containment Isolation Valves 1
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RELIEF REQUEST RV-45 (Continued)
REQUIRED TEST:
Category A valves shall be seat leak tested to a specific maximum amount for each valve in the closed position for fulfillment of their safety function at least once every two years (IWV 3421, 3422, 3426)
BASIS FOR RELIEF:
Even though individual testing of these valves is not performed..
the actual testing methods utilized are set up to provide comparable results and acceptance criteria.
The configuration of the piping systems are such that individual testing is either not possible or practical. Several penetrations do not contain a manual isolation valve that can be used as a-test boundary.
Other penetrations do not have sufficient test connections to allow for individual testing. In some cases a test configuration could be developed using valves outside the containment boundary to individually test the applicable valves-in the reverse direction or to block a leakage path through one valve while attempting to determine leakage through another. However it would be very difficult to obtain accurate and meaningful results.
These test configurations would typically involve considerably larger and more complex test volumes which include test boundary valves that were never intended to be leak tight.
As a resul t, this testing would cause a considerable burden regarding manhours required, additional exposure, maintaining additional test boundary valves and plant outage delays, without providing additional assurance of containment integrity.
Furthermore, for all simultaneous valve leak rate testing, conservatism is applied to assignment of leak rate test results.
l When a leak rate has been obtained for a simultaneous test, that leakage rate is assigned to each valve in the set within the test boundary.
Corrective action is taken on all associated valves unless additional information is obtained which identifies the leaking valve.
Multiple valve leak rate testing, combined with conservatively applied leak rates, outweighs the burden of individual leak rate test attempts.
This testing will identify stuck open valves and provide adequate assurance of containment integrity.
ALTERNATIVE TEST:
Values in each set (penetration) will be leak-rate tested sir 1taneously.
The measured leakage, which represents the comoined leakage from the valves in the set, will be assigned to each valve.
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