ML20056G139
| ML20056G139 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 08/27/1993 |
| From: | Donnelly P CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-REGGD-01.047, RTR-REGGD-1.047 GL-89-04, GL-89-4, NUDOCS 9309020123 | |
| Download: ML20056G139 (19) | |
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/ p0WBf Patrick M Donneny Plant Managn POWERING MICHIGAN'S PROGRESS Big Rock Point Nuc6eer Plant 10209 US 31 North. Cherievoix. MI 49720 August 27, 1993 Nuclear Regulatory Commission Document Cont ol Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -
UPDATE TO INSERVICE TESTING PROGRAM Following the 1992 refueling outage the Big Rock Point Nuclear Power Plant has been performing the Inservice Testing Program in accordance with the 1986 Edition of ASME Section XI. The code usage is in accordance with our Inservice Inspection Program Submittal dated January 22, 1993. The only changes made between our previous code (ASME Section XI 1977s78 Edition) and the 1986 Edition of ASME Section XI for Inservice Testing are 1)The adoption by the code of ANSI \\ASME OM-1-1981 for relief valve testing and 2) The allowance for cold shutdown testing in the 1986 edition of ASME Section XI.
Along with this update the Big Rock Point Plant also will endorse Code Case 465 (Alternate Rules for Pump Testing Section XI, Division 1) following the 1993 refueling outage, as allowed by Regulatory Guide 1.147.
The Big Rock Point Plant Inservice Testing program has been reviewed in accordance with the 1986 Edition of ASME Section XI and Generic Letter 89-04.
The following changes are being made to our previous response dated September 29, 1989.
- 1. All relief valve testing shall be in accordance with ANSI /ASME OM-1-1981 l
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- 2. Pump testing shall be in accordance with ASME/ ANSI OM-1987, Part 6 through j
1987 Addenda.
- 3. The liquid poison system check valves VP-301 and VP-302 shall be tested in l
accordance with Position 2 of Generic Letter 89-04, in that one valve shall l
be disassembled and inspected each refueling outage.
9309020123 930827
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NUCLEAR REGULATORY COMMISSION 2
, BIG ROCK POINT PLANT UPDATE TO INSERVICE TESTING PROGRAM August 27, 1993 Attached is a complete file of Big Rock Points' relief request as revised in accordance with the above and supersedes our previous relief request submittal l
of September 29, 1989.
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Patrick M Donnelly Plant Manager CC: Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point i'
ATTACHMENT l
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ATTACHMENT Consumers Power Company Big Rock Point Plant Docket 50-155 BIG ROCK POINT INSERVICE TESTING PROGRAM RELIEF REQUEST l
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ATTACHMENT INSERVICE TESTING PROGRAM RELIEF REQUESTS The following is a complete listing of the current relief requests applicable to Big Rock Point's IST Program Core Soray Pumos Relief Request unchanged from 1989 submittal.
Electric and Diesel Fire Pump Test Frecuency 1
Relief Request rewritten to remove relief for valves VFP-304 and VFP-309 and j
to reflect new test loop.
I Core Soray Pumps Electric Fire Pumo and Diesel Driven Fire Pumo Bearino Temperature Measurement Relief Request withdrawn - no longer required by code.
Control Rod Drig (VCRD-301 and VCRD-311)
Relief Request i. changed from 1989 submittal.
Emerce u ;iidenser (M0-7052. M0-7053. M0-7062 and MO-7063).
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Relid Request deleted.
Centainment Isolation Valves CV-4091. CV-4092, and CV-4093 i
Relief Request deleted.
Liouid Poison System (CV-4020) i Relief Request deleted.
Liou'd Poison System (VP-300)
Relief Request deleted.
Shutdown Coolino System (M0-7056, M0-7057, M0-7058 and M0-7059)
Relief Request deleted.
Treated Waste Return (CV-4049) and VRW-313)
Removed CV-4049 from relief request. Relief Request for VRW-313 unchanged from 1989 submittal.
j Demineralized Water Supply (VMU-300)
Relief Request deleted.
i ATTACHMENT 2
INSERVICE TESTING PROGRAM RELIEF REQUESTS l
Liouid Poison System (CV-4050)
Relief Request unchanged from 1989 submittal.
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Liauid Poison Supply to Reactor Vessel (VP-301 & VP-302)
Relief request modified to reflect position 2 of Generic Letter 89-04.
I Main Steam Line Drain Isglation Valve (M0-7065)
Relief Request unchanged from 1989 submittal.
Feedwater (VFW-304 & VFW-9) i Relief Request deleted.
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Feedwater (VFW-305)
Relief Request unchanged from 1989 submittal.
Control Rod Drive (CVNC09's & CVNC10's)
Relief Request unchanged from 1989 submittel.
Enclosure Soray System (M0-7064 & M0-7068)
Relief Request unchanged from 1989 submittal.
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Core Spra. System (VPI-300, VPI-306, VPI-307)
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l Relief Request deleted.
l Core Sorav "vstem (VPI-303 & VPI-304)
Relief Request unchanged from 1989 submittal.
l Core Soray Syster, t
' 301 & VPI-302) l l
Relief Request deia l
l Core Soray System (M0-7072)
Relief Request deleted.
Core Sorav System (MO-7071) l Relief Request unchanged from 1989 submittal.
Reactor Depressurization System (SV-4984 - SV-4987) l Relief Requests unchanged from 1989 submittal.
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ATTACHMENT 3
INSERVICE TESTING PROGRAM RELIEF REQUESTS l
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RELIEF RE00EST Item:
Relief request for Core Spray Pumps l
Test Requirement:
Pur.p shall be run on each pump nominally every three months during plant operation and within one week after plant startup from a plant shutdown if not tested during the shutdown.
Basis for Relief:
These pumps are part of the Emergency Core Cooling System. Testing during power i
operations would require a valve lineup which would preclude their performing their required function after a loss of coolant accident (LOCA). In the event of a LOCA, areas which must be entered to change this valve lineup would be untenable. In addition, testing during power operation would require personnel entry into the very high radiation area directly beneath the reactor vessel.
Alternative Testing: Once per reactor cold shutdown and each refueling (but not more frequently than once every three months).
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ATTACHMENT 4
INSERVICE TESTING PROGRAM RELIEF REQUESTS l
REllEF RE0 VEST i
Item: Relief request for Electric and Diesel Driven Fire Pump Test Frequency Test Requirement:
Pump shall be run on each pump nominally every three months during plant operation and within one week after plant startup from a plant shutdown if not tested during the j
shutdown.
i Basis for Relief:
These fire pumps must be tested every three months as required by ASME Section XI IWP testing. To perform ASME Section XI testing of these pumps requires setting up a flow path for fire water through fire hoses to adequately test the pumps.
This flow test, which is the only valid test, will reduce the flow available to the ECC to below that calculated as necessary. Thus, to prevent degradation of the Emergency Core Cooling System, relief is requested to allow testing each reactor shutdown. The granting of this relief request will insure there will be adequate flow available to the Emergency Core Cooling System.
Alternative Testing: Once per reactor cold shutdown and each refueling (but not more frequently than once every three months).
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ATTACHMENT 5
INSERVICE TESTING PROGRAM RELIEF REQUESTS REllEF RE0 VEST System: Control Rod Drive (Print M-106) l Valve: VCRD-310 and VCRD-311 Category: A/C ASME Class:
2 Function: To prevent backflow from containment through the CRD supply line.
Test Requirement:
Exercise quarterly and local leak rate test each reactor shutdown for refueling.
Basis for Relief:
The closing function cannot be verified except during times of local leak rate testing which is performed each reactor rhttdown for refueling per 10CFR50, Appendix J.
t' Alternative Testing:
Local leak rate test each reactor shutdown for refueling.
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ATTACHMENT 6
INSERVICE TESTING PROGRAM RELIEF REQUESTS RELIEF RE0 VEST System: Treated Waste Return (Print M-108)
Valve: Check Valve VRW-313 Category A/C ASME Class:
2 Function: To isolate containment i
Test Requirement:
Exercise valve at least once every three months and j
local leak rate test each reactor shutdown for refueling.
Basis for Relief:
This valve is a passive valve that is in the position that will perform their intended function. Thus, exercising will not provide any additional margin of safety.
Alternative Testing:
Local leak rate test at each reactor shutdown for refueling.
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ATTACHMENT 7
INSERVICE TESTING PROGRAM RELIEF REQUESTS l
i RELIEF RE0 VEST l
System:
Liquid Poison System (Print M-121) 1 Valve: CV-4050 Category:
B ASME Class: 1 Functior:
Isolate flow of liquid poison to recirculation pump suction Test Requirement:
Exercise valve for operability every three months.
i Basis for Relief:
An interlock opens this valve automatically when' either i
recirculating pump is in service. Thus, exercising'this l
valve requires taking both recirculating pumps out of service.
Alternative Testing:
Exercise valve and verify position indication once during any shutdown in which both recirculation pumps are secured, or as a minimum, each. reactor shutdown for refueling.
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ATTACHMENT 8
INSERVICE TESTING PROGRAM RELIEF REQUESTS REllEF RE0 VEST System: Liquid Poison Supply to Reactor Vessel (Print M-121)
Valve: Check Valve in liquid poison supply line to reactor vessel (VP-302) i and Check Valve in liquid poison supply line to recirculating pumps (VP-301).
Category:
C ASME Class: 1 Function: To prevent reactor water backflow through liquid poison line.
Test Requirement:
Exercise valve for operability every three months.
Basis for Relief:
The check valves have no operators.
Exercising these valves by initiating flow in the system would introduce liquid poison into the reactor during operation or shutdown.
Alternative Testing: Visually inspect one valve each reactor shutdown for refueling by removing valve internals per Generic Letter 89-04.
Discussion:
The liquid poison check valves are a Chapman Type V tilting disc check valve which has a three piece body construction. The seat ring, disc and pivot pins are located in the center section which is secured between two flanges with twelve studs. This type of check valve construction lends itself to ease of disassembly, inspection and reassembly and the check valves are isolatable from the reactor vessel.
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ATTACHMENT 9
INSERVICE TESTING PROGRAM RELIEF REQUESTS i
RELIEF RE0 VEST System: Main Steam Line Drain Isolation Valve (Print M-121) l Valve: M0-7065 Category: A ASME Class: 1 Function: To isolate main steam line drain to condenser Test Requirement:
Exercise valve for operability every three months and leak test each reactor shutdown for refueling.
Basis for Relief:
The valve is electrically disabled in the closed i
position and does not have to change position to perform its intended function; thus, no exercising of the valve will be performed.
Alternative Testing:
Note leakage rate through the valve during each NSSS i
hydrostatic test associated with a reactor shutdown for refueling.
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ATTACHMENT 10 INSERVICE TESTING PROGRAM RELIEF REQUESTS l
i REllEF RE0 VEST l
System:
Feedwater Valve:
Feedwater Check Valve VFW-305; Swing Type l
Category: A/C ASME Class: 2 Function: Containment isolation valve l
Test Requirement:
ASME Section XI 1986 IWV-3410 - Valve exercising is not possible during power operation, therefore full stroke test during cold shutdowns is required. Testing at every shutdown'if l
intervals are greater than 3 months or if testing has been completed within the last 3 months testing is not required. Valve disk movement shall be determined by an appropriate indicator.
lWV-3420 - Valves shall be leak tested every two years.
IWV-3520 - Valve exercising per category C requirements are met by fulfilling requirements of category A IWV-3410 requirements.
Alternate Testing:
Perform a 10CFR50 Appendix J leak rate test during each q
refueling.
Basis for Relief:
The valves cannot be exercised during power operation because feedwater flow cannot be interrupted during this time. The check valve seats (closes) when feedwater flow is stopped.
Valve disk movement to the closed position cannot be determined as there are no direct or indirect indications available to make the determination. Disk movement to the open position is i
only possible when feedwater flow is initiated.
Indication of feedwater flow provides the required indication the valve is open. Valve exercise testing l
therefore cannot be accomplished except to verify the l
valve is open by indication of proper feedwater flow.
As a containment isolation valve thu valve will be leak rate tested each refueling outage in accordance with 10CFR50 Appendix J requirements.
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ATTACHMENT 11 INSERVICE TESTING PROGRAM RELIEF REQUESTS RELIEF RE0 VEST System: Control Rod Drive (Print M-122)
Valve: Scram Inlet (CVNC09) and Outlet (CVNC10) Isolation Valves (32 sets of 2 valves)
Category: B ASME Class: 2 Function: To cause a control rod drive to insert rapidly lest Requirement:
Exercise valve for operability every three months.
Basis for Relief:
Exercising these valves would cause the associated control rod to scram.
Alternative Testing:
Exercise valves in accordance with Technical Specifications requirements (this is in accordance with NRC Generic Letter 89-04).
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ATTACHMENT 12 INSERVICE TESTING PROGRAM RELIEF REQUESTS RELIEF RE0UEST System:
Enclosure Spray System (Print M-123)
Valve: M0-7064, M0-7068 Category: B ASME Class: 2 Function:
Enclosure spray isolation valves Test Requirement:
Exercise valve for operability every three months.
Basis for Relief:
Exercising these valves during power operation would result in spraying water on energized electrical equipment inside containment. M0-7064 and M0-7068 cannot be exercised during cold shutdowns because the fire system header must be taken out of service and drained to allow the exercising of the valves. This will pose an unwarranted fire hazard if the fire system is not available in the containment. Testing during each reactor shutdown for refueling presents a more acceptable risk as far as fire suppression capabilities in the containment.
Alternative Testing:
Exercise valves each reactor shutdown for refueling.
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1 ATTACHMENT 13 INSERVICE TESTING PROGRAM RELIEF REQUESTS RELIEF REQUEST System: Core Spray System (Print M-123) i i
Valve:
Primary Check Valves (VPI-303 and VPI-304)
Category: A/C ASME Class:
Function:
Primary check valves in the core spray lines to prevent reactor pressure from pressurizing lines if the isolation valves were opened.
Test Requirement:
Exercise valve for operability every three months.
Basis for Relief:
The primary check valves have no operators. The valves cannot be opened against operating reactor pressure by initiating flow through these lines, because core spray system pressure is much less than operating reactor pressure. During shutdown, the initiation of flow through these lines would introduce non-reactor grade i
water into the core.
The only means to insure proper valve operation is to disassemble and inspect the valve during each reactor shutdown for refueling.
There exists no method to insure disc movement torque requirements are met. -The valve will be inspected and verified that the disc is free to move.
Alternative Testing: Disassemble and inspect each reactor shutdown for refueling,
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INSERVICE TESTING PROGRAM RELIEF REQUESTS RELIEF RE0 VEST System: Back-up Core Spray.
Valve: M0-7071 Category: A ASME Class: 1 Function:
Isolation valve between ' primary system and-core spray system.
Test Requirement:
Local leak rate test each ' reactor shutdown for
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refueling.
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Basis for Relief:
The back-up core _ spray system has three valves in series M0-7070, VPI-303 and M0-7071 which perform as isolation-l valves between the lower pressure core spray system (150 psig) and the primary coolant system (1335 psig).
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.There is a' telltale' located between M0-7070 and VPI-303 which would indicate leakage past VPI-303 and M0-7071.
M0-7070 and M0-7071:areyfull. stroked every month during-plant operation. During this test.the operator is i
cautioned to ensure.that core. spray: pressure _does not i
increase above~ 170 psig which would indicate leakage l
through the valves. When MO-7070.is stroked the flow through the telltale is _ checked and when M0-7071-is:
l stroked check valve VPI-303 is checked to show that it is adequately. seated.; By having these thre2 valves-in j
series and performing the monthly' stroke testing'of j
M0-7070 and M0-7071 there is adequate insurance-that 1
there is proper isolation between the two systems.
Alternative Testing: flone i
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ATTACHMENT 15 INSERVICE TESTING PROGRAM RELIEF REQUESTS RELIEF REQUEST System:
Reactor Depressurization System (Print A-203)
Valve:
SV-4984, SV-4985, SV-4986 and SV-4987 Category: B i
ASME Class:
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Function: Depressurizing Valve 3
Test Requirement:
Exercise valve for operability every three months.
Basis for Relief:
The valve cannot be full stroke exercised unless continuous primary system pressure is applied. With the isolation valve closed, pressure in the spool piece i
between the isolation valve and the depressurizing valve is relieved before the depressurizing valve reaches the full stroked position. With the isolation valve open a continuous steam blowdown of the primary system into containment would result.
Partial stroke exercising of the valve has been demonstrated to be a significant contributor to chronic pilot valve seat leakage.
Alternative Testing:
Full stroke exercise the depressurizing valve each refueling outage, but not to exceed eighteen months.
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INSERVICE TESTING PROGRAM RELIEF REQUESTS
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RELIEF REQUEST l
System:
Reactor Depressurization System (Print A-203)
Valve: SV-4984, SV-4985, SV-4986 & SV-4987 Category:
B ASME Class:
1 Function:
Depressurizing Valve l
Test Requirement:
Time power operated valves in accordance with IWV-3413 l
l Basis for Relief:
The reactor depressurizing valves are Target Rock l
solenoid valves which stroke in less than one second.
i In accordance with Position 6 of Attachment 1 of NRC l
Generic Letter 89-04, variations in stroke times for i
this type of fast acting valve is not a meaningful measurement of valve degradation.
l Alternative Testing: These valves shall be assigned a maximum stroke time limit of 2 seconds.
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