ML20058D887
| ML20058D887 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 07/23/1982 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| TAC-48653, NUDOCS 8207270430 | |
| Download: ML20058D887 (20) | |
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4 mumm Portland General ElectricCompany r
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MD,m /enne w t July 23, 1982 Director of Nuclear Reactor Regulation-ATTN:
Mr. Robert A. Clark, Cnief Cperating Reactors Branch No. 3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Clark:
Inservice Testing Relief Request Pursuant to 10 CFR 50.55(a), PGE hereby requests relief from certain inservice testing (IST) requirements for pumps and valves at the Trojan Nuclear Pla The attached relief requests are based on the require-ments given in Section XI of the Winter 80 Addenda to the 1980 Edition of the ASME Boiler and Pressure Vessel Code. Similar requests for many of the pumps and valves were previously transmitted to the NRC and given interim approval by the NRC letter dated June 10, 1980. Alternate testing requirements have been proposed in each case.
The attached list does not include relief requests for valves which cannot be full stroke exercised during normal operation, but are being part stroke tested during normal operation and/or full stroke exercised during cold shutdown in accordance with Paragraphs IWV-3412 and -3522.
A check for $4,000 is attached in accordance with 10 CFR 170.
Sincerely, C)'l 3J 0[I' Bart D. Withers Vice President
\\rV Nuclear 1/c)oO.ct3 Attachment c: Lynn Frank, Director State or Oregon Department of Energy F207270430 820723 PDR ADOCK 05000344 P
PDR 121 S W Sawon Seeet. Portand. O'egon 97204
I 3.2 RELIEF REQUESTS FOR PUMPS The Code of Federal Regulations,10 CFR 50.55a(g)(5)(iii), states that, "If the licensee has detemined that conformance with certain code requirements is impractical for his facility the licensee shall notify the Commission and submit information to support his deteminations."
By interpretation, testing of pumps which does not confom to the stan-s,
dard test requirements for measurement of specific parameters or for the frequency of performance of tests is assumed to be a nonconformance.
This section identifies those pumps for which Trojan Nuclear Plant is in nonconfomance with the standard test requirements aild provides the basis for relief frca testing and the provisions for alternate testing of those pumps when applicable.
t 3.2.1 Service Water System: Pumps P108A, P108B, P108C
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Code Class: ASME VIII, Division 1 s
Function:
The service water pumps provide ccoling and makeup water for safety-related and non-safedy-related
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equipment and systems. The pumps are also used for dilution of liquid radwaste during discharge.
Test Requirement: Measure / observe pump inlet pressure, vibra-tion amplitude, bearing temperature, and lubricant.
l Basis for Relief: " Instrumentation Not Originally Provided."
ASME VIII pumps at Trojan were not required to be l
designed for testing for cperational readiness as per 10 CFR 50.55a(g).
The pumps are totally submerged inside the Intake Structure. Pump bearings are inaccessible and the instrumentation required for measurement of pump 3.2-1 PGE-1022 Amendment 2 (December 1981)
w inlet pressure, vibration. amplitude, and bearing temperature was not provided in the original system design.
Alternate Testing: Inlet pressure for these pumps will be determined by measuring the Intake Structure water level and substituting the measured value into the following formula which relates this level to the pump inlet pressure:
s Pi = 0.433 (24.75 - Intake Structure level).
The pumps are submerged in the Intake Structure and are not accessible for attachment of transducers for displacement measurement of vibration amplitudes during pump operation. The pump motor inboard bearing will be periodically monitored for vibration amplitude. Motor inboard bearing vibration measure-ments provide indication of pump shaft alignment and deterioration. The pump bearing vibration amplitude will not be measured.
The pump bearing temperature will not be measured, and the lubricant will not be observed.
l 3.2.2 Diesel Fuel Oil System: Pumos P144A & P144B Code Class: ASME VIII, Division 1 Function:
The diesel oil transfer pumps provide flow of fuel oil from the diesel oil storage tanks to the fuel oil day tanks.
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3.2-2 PGE-1022 Amendment 2 (December 1981)
s Test Requirement: Measure pump inlet pressure, differential pressure, flow rate, vibration amplitude, bearing temperature, and lubricant.
l Basis for Relief: " Instrumentation Not Originally Provided."
ASME VIII pumps at Trojan were not required to l
be designed for testing for operational readiness as per 10 CFR 50.55a(g).
These pumps are located inside the diesel oil stor-age tanks. The pumps are inaccessible and instru-mentation was not provided for measurement of inlet pressure, differential pressure, flow, vibra-tion amplitude, or bearing temperature.
Alternate Testing: Pump discharge pressure will be measured and the inlet pressure will be calculated frcm tank level and the suction head on the pump. The differ-ential pressure will be taken as the difference between pump discharge pressure and calculated inlet pressure.
The pumps are enclosed within the diesel oil storage tanks and accessibility is not available for measuring pump vibration amplitude.
The pump bearing temperature and flow rate will not be measured, and the lubricant will not be observed.
3.2.3 Feedwater System: Pumos P102A and P1023 Code Class: ASME VIII, Division 1 3.2-3 PGE-1022 Amendment 2 (December 1981) l
Function:
The auxiliary feedwater pumps provide a backup to the normal feedwater pumps to ensure the safety of the Plant and protection of steam generators when the normal feedwater pumps are unavailable.
Test Requirement: Measure the flow rate every 3 months.
Basis for Relief: " Instrumentation Not Originally Provided."
ASME,Section VIII, pumps at Trojan were not required to be designed for testing for operational readiness, as per 10 CFR 50.55a(g). Instrumenta-tion was not pr'ovided for measurement of flow rate.
Alternate Testing: The inlet pressure, differential pressure, rotative speed, bearing temperature, and vibration amplitude will be measured for each of these pumps.
Measurement of these pump parameters will provide evidence to assess the operational readiness of these pumps. Flow rate will not be measured.
3.2.4 Chemical and Volume Control System: Pumos P205A and P205B' Code Class: 2 l
Function:
These pumps normally are not operating when the positive displacement charging pump is available, but in the event that the charging ficw requirements exceed the capacity of the positive displacement charging pump, one of these pumps is put online and the positive displacement charging pump is shut down.
During an LOCA, both of these pumps operate as part of the Safety Injection System.
Test Requirement: Measure the flow rate every 3 months.
3.2-4 PGE-1022 Amendment 2 l
(December 1981)
Basis for Relief: " Instrumentation Not Provided." Class 2 pumps at Trojan were not required to be designed for testing for operational readiness, as per 10 CFR 50.55a(g). Instrumentation was not provided for measurement of flow rate.
Alternate Testing: The inlet pressure, differential pressure, bearing temperature, and vibration amplitude will be measured for each of these pumps. Measurement of these pump parameters will provide evidence to assess the operational readiness of these pumps.
Flow rate will not be measured.
3.2.5 Chemical and Volume Control' System: Pumps P211A and P211B Code Class: 3 Function:
Normally, one of these pumps is aligned with one boric acid tank and starts on demand frcm the Reactor Makeup Control System. Emergency boration, the supplying of 4-weight percent boric acid solution to the suction of the charging pumps; can be acccmplished by either/or both of these pumps.
These pumps are also used to transfer 4-weight percent boric acid solution frem the batching tank to the boric acid tanks.
Test Requirement: Measure the ficw rate every 3 months.
Basis for Relief:
" Instrumentation Not Provided." Class 3 pumps at Trojan were not required to be designed for testing for cperational readiness, as per 10 CFR 50.55a(g). Instrumentation was not provided for measurement of ficw rate.
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Alternate Testing: The inlet pressure, differential pressure, i
bearing temperature, and vibration amplitude will be measured for each of these pumps. Measurement 1
of these pump parameters will provide evidence to assess the operational readiness of these pumps.
Flow rate will not be measured.
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0 4.2 RELIEF REQUESTS FOR VALVES The Code of Federal Regulations,10 CFR 50.55a(g)(5)(iii), requires that "If the licensee has determined that conformance with certain code requirements is impractical for his facility the licensee shall notify the Commission and submit information to support his determinations."
By interpretation, any valves which do not conform to the standard test requirements for measurement of specific parameters or for the frequency.of the test are assumed to be in nonconformance. This section identifies those valves for which testing under this program does not comply with the standard test requirements and provides the bases for relief from testing and provisions for alternate testing.
4.2.1 Reactor Coolant System 4.2.1.1 Valves: 8046 and 8047 Catego ry: AC Class:
2 Function: These valves are internal Containment isola-tion valves which prevent backflow of Contain-ment / Pressurizer Relief Tank contents under accident conditions.
Test Requirement: Exercise for operability every 3 months.
Basis for Relief: These valves cannot be verified shut during power operation because the test con-nections are located inside the Containment.
The only available method to verify valve 4.2-1 PGE-1022 Amendment 2 (December 1981)
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4 cicsure is during leak rate testing during i
refueling outages.
Alternate Testing: These valves will be exercised for verification of operability during each refueling.
4.2.2 Residual Heat Removal System 4.2.2.1 Valve: 8958 Category: C Class:
2 Function: This valve prevents backflow frca RHR suction header to the refueling water storage tank.
Test Requirement: Exercise for operability every 3 months.
Basis for Relief:. Exercising this valve requires the RHR pumps drawing suction on the R'iST.
Operating modes do not allow this because there is no place to store the water unless initiating large scale RWST recirculation (opening manual valve 8735). However, this is not feasible due to the RHR system operat-i ing in a degraded condition. Cold shutdown is not feasible because the RHR is in circulation to the RCS. The only feasible Plant condition for which this valve can be exercised is during refueling when the RHR system is utilized to fill the refueling cavity.
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4.2-2 PGE-1022 Amendment 2 (December 1981)
j Alternate Testing: This val've will be full-stroke exer-cised during refueling outages when the refuel-ing cavity is being filled.
4.2.2.2 Valves: HCV-606 and HCV-607 Category: B Class:
2 Function: These valves permit remote control of flow through the heat exchangers.
Test Requirement: Exercise to measure strcke time every 3 months.
Basis for Relief: These valves are remotely centrolled for cpening and closing by manual adjustment of a potentiometer. The strcke times of these valves are dependent on how fast the operator adjusts the potenticmeters that control the valves' cpening and closing.
Alternate Testing: These valves will be tested to verify smooth operation over their full range every 3 months.
4.2.3 Safety Injection System 4.2.3.1 Valves: 8956A, 8956B, 8956C, and 8956D Category: AC Class:
1 4.2-3 PGE-1022 Amendment 2 (December 1981)
o Function: These normally-closed valves prevent backflow from the RCS into the accumulators during normal cperation.
Test Requirement: Exercise for operability every 3 months.
Basis for Relief: During normal operation, the accumula-tor cannot overccme RCS pressure. Full-strcke testing is not feasible due to limited Plant conditions for testing.
Alternate Testing: These valves will be partial-stroke exercised during cold shutdown.
4.2.3.2 Valve: 8968 Catego ry: AC 2
Class:
2 i
Function: This internal isolation valve prevents backflow out of the Containment frca the accumulators and is on the nitrogen overpressure supply line.
Test Requirements: Exercise for operability every 3 months.
Basis for Relief: There are no provisions for verifying the valve to be in the shut position during normal cperation.
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Alternate Testing: This valve will be exercised and veri-fied shut durir.g leak rate testing at refueling outages.
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1 4.2.3.3 Valves: M0-8803A and M0-88038 f
Catego ry: B Class:
2 Function: These valves isolate the boron injection tank from the charging pumps during normal operation. These valves are interlocked to open on a safety injection signal.
Test Requirements: Exercise for operability every 3 months.
Basis for Relief: When the positive displacement charging pump (P-217) is inoperable, the centrifugal pumps are run to provide normal charging flow. Exercising these valves while the centrifugal charging pumps are operating will dilute the baron injection tank (BIT) concentration and/or subject the BIT to a pressure shock. There is a specified number of design pressure shocks for the BIT, and a low limit for operability for boron concen-tration.
Alternate Testing: These valves will be full-stroke exercised with the Plant in Modes 4, 5, or 6 when these valves are not testable in Modes 1, 2, or 3.
Otherwise, they will be exercised l
for operability every 3 months.
4.2-5 PGE-1022 i
Amendment 2 (December 1981)
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4.2.4 Containment Spray System 4.2.4.1 Valves: 10-HCB-CK (two) i Catego ry: C Class:
2 3
Function: These valves prevent backflow of air from the Containment atmosphere thrcugh the Containment spray ring header.
Test Requirement: Exercise for operability every 3 months.
Basis for Relief: These valves do not have provision for testing under norm 51 conditions. Exercising the valves would require injection of the test medium into the Containment through the spray i
nozzles with no means available for verifica-tion of ficw. Equipment damage and require-ments for extensive cleanup of the Containment would result.
Alternate Testing: These valves are partial-strcke exer-cised during Containment air flow testing at a maximum interval of 5 years under Technical Specification 4.6.2.1.
l 4.2.4.2 Valves: 14-HCB-CK (two) l Category: C Class:
2 i
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Function: These valves prevent backflow into the RWST from the Containment spray suction header.
Test Requirement: Exercise for operability every 3 months.
Basis for Relief: Full-stroke exercising of these valves would require injection of the test medium into the Containment. Equipment damage and require-ments for extensive cleanup of the Containment would result.
Alternate Testing: These valves will be partial-stroke exercised with flow thrcugh the Containment spray pump miniflow lines every 3 months.
4.2.5 Main Steam System 4.2.5.1 Valves: CV-2210, CV-2230, CV-2250, and CV-2270 Catego ry: BC Class:
2 Function: These valves prevent reaching the safety valve setpoint during transients and dissipate reactor decay heat to the atmosphere if the main condenser is not available.
Test Requirement: Exercise to measure stroke time every 3 months.
Basis for Relief: Testing these valves every 3 months increases the normal number of times each valve cpens against a differential pressure, thus deteriorating the valve seat and 4.2-7 PGE-1022 Amendment 2 (December 1981) i 4
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increasing the likelihood of causing leakage.
These valves are remotely controlled for opening and closing by manual adjustment of a controller. The stroke times of these valves are dependent on how the controller is calibrated.
Alternate Testing: These valves will be exercised to verify smooth operation only over their full range during cold shutdown.
4.2.5.2 Valves: 28-EBB-CK (four)
Catego ry: C Class:
2 Function: These valves perform an accident-related func-tion in that they are required to close in the event of a steam line break in Containment in 4
order to prevent blowing down of more than ene steam generator to Containment.
Test Requirement: Exercise for operability every 3 months.
Basis for Relief: During normal operation, the main steam pressure cannot be overccme, and as a result these valves cannot be exercised.
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Alternate Testing: These valves will be full-strcke exer-cised for verification of cperability during refueling.
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4.2.5.3 Valves: 3-EBD-CK (four)
Category: 'C Class:
Function: These valves prevent backflow from the steam i
turbine-driven auxiliary feedwater punp to the i
mainsteam lines.
Test Requirement: Exercise for operability every 3' months.
I Basis for Relief: There are no provisions for verifying that the valve is in the shut position during normal operation.
Al ternate Testing: These valves will be checked every 3 months to verify that they arc in the open position and will be exercised to verify o; era-bility in the closed position at each refueling cutage.
i 4.2.6 Clean Radioactive Waste System 4.2.6.1 Valve: 1-GSB-CK Category: AC 3
Class:
2 Function: This valve is a Containment isolation valve for the N2 supply line to the reactor coolant drain tank and prevents backflow out of Containment.
4.2-9 pGE-1022 Amendment 2
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Test Recuirement: Exercise for operability every 3 months.
Basts for Relief: The valve can only be verified in the closed position during leak rate testing at refueling outage.
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Alternate Testing: Exercise for operability at each refueling outage.
4.2.7 Instrument and Service Air System 4.2.7.1 Valves: CV-4471 and 2-HBE-CK (two)
Category: A and AC, respectively
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Class:
2 Function: These normally-open series valves are Contain-ment isolation valves for the instrument air supply to pneumatic valves and instrumentation inside the Containment. The valves close on receipt of a Containment isolation signal.
Test Requirement: Exercise for operability every 3 months.
Basis for Relief: Failure of either of these valves in a closed position removes the air supply to the Containment air-operated valves and pneumatic instrumentation. 2-HSE-CK can only be veri-fied shut during leak testing at refueling outages.
Alternate Testing: These valves will be full-stroke exer-cised for verification of operability during leak rate testing at refueling.
4.2-10 PGE-1022 Amendment 2 (December 1981)
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4.2.8 Generic Relief Recuests f
4.2.8.1 Valves: Containment Isolation Yalves i
Category: A Class:
1 and 2 Function: These valves provide Containment isolation during reactor operation and/or isolate the Containment to prevent the release of radio-i active products f'olicwing a design accident.
Test Requirement: Test for seat leakage rate at each l
refueling.
Basis for Relief: The Containment isolation valves are tested for seat leakage under the criteria of Appendix J to 10 CFR 50. These valves are tested and analyzed for seat tightness in I
accordance with the Trojan Nuclear Plant
" Containment Local Leak Rate Test". This procedure provides for local leak rate testing of valves. The acceptance criteria for allowa-ble leakage rate under Appendix J to 10 CFR 50
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varies frca the acceptance criteria of Subsec-tion IWV of ASME,Section XI, in that the allowed leakage is based on the total Contain-ment leakage rate rather than on individual valve seat leakage criteria. This test program provides adequate documentation and individual i
analysis for valves to verify maintenance of Containment integrity. Failure of any valve to i
4.2-11 PGE-1022 Amendment 2 1
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f provide adequate seat tightness in maintaining Containment integrity will require the same corrective action for repair and replacement of the valve. Therefore, based on provisions in Section XI which allow the owner to specify the valve seat leakage criteria, testing under the Section XI requirements would only i
require duplication of documentation without l
any added benefit as far as testing or ana'lyzing of test data for assurance of leakage integrity.
I Alternate Testing: These valves are tested for seat leak-age rate during local leakage rate testing in accordance with Appendix J to 10 CFR 50 and will'not be tested under this program.
j 4.2.8.2 Valves: - WASH-1400, Event V Configuration Valves I
Category: A 4
Class:
1 i
Function: These valves are designated from a configura-I tion of in-series check valves which provide a boundary between a high-pressure system and a system with a design pressure below that of the l
normal operating pressure of the high-pressure t
system.
Test Requirement: Test for seat leakage rate at each cold j
- shutdown, l.
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I Basis for Relief: The present systen at Trojan for testing in-series check valves is designed for testing the second in-series check valve at normal operating pressure only in tne event that the first valve demonstrates leakage.
The WASH-1400 report does not consider added assurance of protection frcm periodic testing of the first valve.
Alternate Testing: These valves will be leak tested at reduced pressures prior to entering flode 2 after each refueling and prior to entering Mode 2 whenever the Plant has been in Cold Shutdown for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or more, and if leakage testing has not been performed in the previous 9 months.
4.2.8.3 Valves: Valves Designated for Review Under the Criteria for Appendix J to 10 CFR 50 These valves were identified by NRC staff during the preliminary meeting for resolving IST cccments and-are being reviewed by the HRC for applicability to Appendix J,
" Containment Boundary Criteria". The valves have been included within this program for administrative documenta-tion only. Testing of these valves will be reevaluated i
upon ccmpletion of the NRC review.
4.2-13 PGE-10%%
Amencment 2 (Decemoer 1981)
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