ML20058N718

From kanterella
Jump to navigation Jump to search
Forwards Rev 10 to WCOP-02, IST Program for Pumps & Valves, in Response to NRC 930312 Request.Rev Consists of Relief Requests Written Against Requirements of Asme/Ansi OMa-1988,Part 10
ML20058N718
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 12/14/1993
From: Carns N
WOLF CREEK NUCLEAR OPERATING CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20058N720 List:
References
WM-93-0152, WM-93-152, NUDOCS 9312220227
Download: ML20058N718 (8)
v • d • e


Text

.

W8LF CREEK ' NUCLEAR OPERATING CORPORATION i

l Neil S. "Buzt" Carns Pfesident md Chet Executive o!tcer December 14, 1993 l WM 93-0152 U. S. Nuclear Regulatory Commission '

ATTN: Document Control Desk Mail Station F1-137 Washington, D. C 20555 Referencc: 1) Letter WM 93-0030 dated February 25, 1993, from B.

D. Withers, WCNOC to NRC t

2) Letter dated March 12, 1993, from S. C. Black,
  • NRC, to B. D. Withers, WCNOC l

Subject:

Docket No. 50-482: Submittal of Revised Inservice Testing Program and Relief Requests i

Gentlemen:

The purpose of this letter is to provide Wolf Creek Generating Station's (WCGS) revised Inservice Testing (IST) program and relief requests written against the requirements of ASME/ ANSI OMa-1988, Part 10. Reference 2 approved relief request VR-24 for the adoption of ASME/ ANSI OMa-1988, Part 10 with an exception that referenced Part i requirements would not be included.  ;

Specifically, Reference 2 requested that WCGS's revised IST program be '

submitted, including relief requests written against the requirements of ASME/ ANSI OMa-1988, Part 10 where the requirements could not-be met (including relief requests previously granted but written to a different version of the Code), justification for deferral of stroke testing in accordance with paragraphs 4.2.1.2 and 4.3.2.2 of ASME/ ANSI OMa-1988, Part 10, and the ,

schedule for implementation of the test plans. The attachment to this letter  ;

provides relief requests as required by 10 CFR 50.55 (f) (5) (iii) , which are  :

written against the requirements of ASME/ ANSI OMa-1988, Part 10, including relief requests previously granted but written to a different version of the Code.

The enclosure to this letter provides for information, WCGS's revised IST program as documented in WCOP-02, " Inservice Testing Program for Pumps and Valves," Revision 10, including justification for deferral of stroke testing, which is included in the " Notes" section of WCOP-02.

i

'.T. , h., w tj o.Y) n PDR ADOCK 05000482 P 1)h PDR P O Box 411/ Burnngton. KS (6839 / Phone. (310) 3fA 8831

{j

(! (

An Equal Oppoqunny E rnproym M WC'VG h

4 1

l 1

WM 93-0152 '

Page 2 of 2 I

i Reference 1 provided a revised schedule for the completion of corrective actions identified in Licensee Event Report . 4 82/91-007-00 and Response to Violation 482/9209-01. As part of the corrective actions associated with these events, Wolf Creek Nuclear Operating Corporation committed to undertake an IST program upgrade, including a complete technical review of IST procedures to ensure their technical adequacy and compliance with the ASME l Code. Specifically, Reference 1 extended the original completion date for the l

IST program upgrade to October 29, 1993, since ASME/ ANSI OMa-1988, Part 10 was  ;

being adopted in place of Section XI INV and would delay the completion of the  :

upgrade. On October 13, 1993, the upgrade of the IST program was' completed. j This upgrade included the revision of all IST valve procedures to incorporate  !

the guidance in NRC Generic Letter 89-04, " Guidance on Developing Acceptable  :

Inservice Testing Programs," and to upgrade to ASME/AASI OMa-1988, Part 10.  !

Also, an IST Design Basis document, which identifies the testing requirements  ;

i for each component and the basis for inclusion or exclusion in the IST program, was created and all discrepancies discovered during an IST program [

t self-assessment and a NRC IST program inspection were resolved. Therefore, I

following the IST program upgrade, WCGS's valve testing program is currently j being implemented in accordance with the requirements of ASME/ ANSI OMa-1988, ,

l Part 10, except for relief valves, and all testing will be completed on the appropriate valves utilizing the requirements of ASME/ ANSI OMa-1988, Part 10, by March 31, 1994. l l If you have any questions concerning this matter, please contact me at (316) I l

364-8831, extension 4000, or Mr. Kevin J. Moles at extension 4565  ;

Very truly yours, I

Neil S. Carns [

President and  !

Chief Executive Officer J

NSC/jra Attachment Enclosure l

cc: J. L. Milhoan (NRC), w/ attachment & enclosure G. A. Pick (NRC), w/ attachment & enclosure W. D. Reckley (NRC) , w/ attachment & enclosure L. A. Yandell (NRC), w/o i

I Attachment to WM 93-0152 Page 1 of 5 RELIEF REQUEST NO. YR-6 VALVE (S):

KJ PV-1 A, KJ PV-1B, KJ PV-101 A and KJ PV-101B CATEGORY:

B FUNCTION:

Provides control air for actuation of the Main Air Start Valves.

l TEST REQUIREMENT:

ASME/ ANSI OMa-1988, Part 10. Section 4.2.l(b) and 4.2.1.8 B ASIS FOR RELIEF:

Valve Stoke Time cannot be measured. Rese valves are Solenoid operated and are enclosed with the Solenoid. The valves have no Position Indication Desices. These Air Start Valves are required to start the associated Diesel. Diesel Start Time is a!Tected by Valve Stmke Time.

Valve degradation can be detected by ensuring the Diesel comes up to speed in s 12 seconds and by observing approximately equal pressure drops in the Starting Air Tanks. Therefore, Diesel Start Time and Starting Air Tank Pressure changes will provide indication of valve performance.

l l ALTERNATE TESTING:

I t

i l Proper operation of these valves will be veriDed by measming Diesel Start Times and observing i

! Starting Air Tank Pressure Changes.

l l

l I

i l

l

Attachment to WM 93-0152 Page 2 of 5 ,

RELIEF REQUEST NO. VR-11 i l

VALVE (S):

BB-8010A, BB-8010B and BB-8010C CATEGORY:

C FUNCTION:

The Pressurizer Safety Relief Valves provide overpressurization protection for the Pressurizer.

TEST REQUIREMENT:

Valves with Remote Position Indicators shall be observed at least once every 2 yean to verify that valve operation is accurately indicated. (ASME/ ANSI OMa-1988. Part 10, Section 4.1)

B ASIS FOR RELIEF:

If these valves are actuated for the Position Indication Test they need to be retested to ensure the Set Relief Pressure is correct. This involves increased testing and unnecessary radiation exposure to test personnel.

ALTERNATE TESTING:

The valve's Lift Indicating Switch Assembly will be detached form the Valve spindic. A magnet and a Lift Indicating Switch Setting Tool will be used to simulate valve OPENING and valve CLOSING Position which verifies Lift Indicating Switch Assembly Position with Remote i Position Indication.

Attachment to WM 93-0152 Page 3 of 5 RELIEF REQUEST VR-25 VALVE (S):

EN-V003, EN-V009 CATEGORY:

C FUNCTION: ,

OPEN: Provides suction to Containment Spray Pump from the RWST on initiation of Containment Spray u hen in the injection mode following a LOCA or MSLB inside containment.

CLOSED: Prevents highly contaminated water from the Containment Recirc Sump from i retummg to the RWST after shifting to the Recirc Mode following a LOCA.

i TEST REQUIREMENT.

l As an alternative to tlic testing in OMa-1988, Part 10, Section 4.3.2.4(a) or 4.3.2.4(b),

i disassembly every refueling outage to verify operability of check valves may be used. (OMa-1988 part 10 section 4.3.2.4(c)) Position 2 of Generic Letter 89-04 will be used to allow for one valve to be disassemblul cach outage to determine the condition of the valve and the need to disassemble the other valve.

( BASIS FOR RELIEF:

It is impractical to stroke open test these valves at any time with flow since this would result in spraying containment. Due to radiation / contamination concerns it is impractical to disassemble both valves every refueling. The valves will be sample disassembled as allow ed per OMa-1988 part 10 section 4.3.2.4(c) and Gencric Letter 89-04.

It is also impractical to test these valves closed doe to there not being a drain or test line located upstream of the check valve which could be used to measure the leakage rate to determine if the check valve was closcd. Due to radiation / contamination concerns it is impractical to disassemble both valves every refueling. Although disassembly is allowed by OMa-1988 part 10, neither OMa-1988 part 10 nor Generic Letter 89-04 discusses sample disassembly for verifying closure capability. However, the Minutes Of The Public Meetings On Generic Letter 89-04 states sample disassembly may be acceptable (with relief) depending on whether verification by flow or pressure measurements is practical. It is practical to determine the closed position of the valve by flow or pressure measurements.

ALTERNATE TESTING:

For both open and close verification, these check valves will be partial flow tested quarterly and one valve each outage will be disassembled, inspected, and manually full stroked during each refueling. If the full stroke capability of the disassembled valve is in question, the other valve will be disassembled, inspected, and manually full stroked during the same outage.

i I - - -

Attachment to WM 93-0152 Page 4 of 5 RELIEF REQUEST VR-26 1

VALVE (S):

EN-V013, EN-V017 CATEGORY:

C FUNCTION:

OPEN: Allows discharge from containment spray to flow to spray headers to mitigate the consequences of a LOCA, MSLB or HELB inside containment.

CLOSED: Containment isolation valve. Maintains containment integrity in the event of a containment spray failure.

TEST REQUIREMENT:

As an alternative to the testing in OMa-1988, Part 10. Section 4.3.2.4(a) or 4.3.2.4(b),

disassembly every refueling outage to verify operability of check valves may be used. (OMa-1988 part 10 section 4.3.2.4(c))

BASIS FOR RELIEF:

It is impractical to stroke open test these valves at any time with flow since this would result in spraying containment. Due to radiation / contamination concems it is impractical to disassemble both valves every refueling.

I ALTERNATE TESTING:

For both open and close verification, one check valve cach outage will be disassembled, inspected. and marmally full stroked during each refueling.

1 i

{

l

Attachment to WM 93-0152 Page 5 of 5 RELIEF REQUEST VR-27 VALVE (S): i FC-V001, FC-V024, FC-V002 and FC-V025 CATEGORY:

C FUNCTION:

OPEN: Provides driving steam to the turbine of turbine driven aux feedwater pump from steam generator for normal and emergency cool down of the RCS.

l CLOSED: Prevents diversion of steam from turbine driven aux feedwater pump in the event of a main steam line failure.

l

TEST REQUIREMENT

As an alternative to the testing in OMa-1988 Part 10 Section 4.3.2.4(a) or 4.3.2.4(b),

l disassembly every refueling outage to verify operability of check valves may be used. (OMa-1988 part 10 section 4.3.2.4(c)) Position 2 of Generic Letter 89-04 will be used to allow for one valve to be disassembled cach outage to determine the condition of the valve and the need to disassemble the other valve.

BASIS FOR RELIEF:

l It is impractical to test these valves closed due to there not being in drain or test line located between either pair of check valves. Although disassembly is allowed by OMa-1988 part 10, neither OMa-1988 part 10 nor Gencric Letter 89-04 discusses sample disassembly for verifying closure capability. Howcrer, the Minutes Of The Public Meetings On Generic Letter 89-04 states sample disassembly may be acceptable (with relief) depending on whether verification by flow or prc;sure measurements is practical. It is not practical to determine the close position of these valves by flow or pressure measurements is practical. It is not practical to determine the close position of these valves by flow or pressure measurements.

I ALTERNATE TESTING:

For stoke open verification, these check valves will be partial flow tested quarterly and full flow tested cold shutdowns. For closure verification one valve will be disassembled, inspected, and manually full stroked during each refueling. If the full stroke capability of the disassembled valve is in question, the other valve will be disassembled, inspected, and manually full stroked during the same outage.

l

)

i Enclosure to WM 93-0152 '

I 1

l l

1 WCOP-02

" Inservice Testing Program for Pumps and Valves" l

i l

l l

1 l

i i

)

I I

I I

i

Retrieved from "https://kanterella.com/w/index.php?title=ML20058N718&oldid=2694721"