ML20073Q601
| ML20073Q601 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 05/20/1991 |
| From: | TOLEDO EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9105300181 | |
| Download: ML20073Q601 (3) | |
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f CENTERIOR ENERGY Donald C. Shelton M M3*" N"#
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Docket Number 50-346 License Number NPF-3 Settal Number 1936 May 10, 1991 United States Nuclear Regulatoty Commission Document Control Desk Vashington, D. C.
20555
Subject:
Proposed Alternative to ASME Boller and Ptessure Vessel Code Section XI Test Hequirements f or Pr escut izer Code Saf ety Relief Valves Gentlemen:
American Society of Hechanical Engineers ( ASHC) Boiler and Pressure Vessel (B&PV) Code, 1986 Edition,Section XI, IVV-3510, Safety Valve and Relief Valve Tests, references ANSI /ASME OH-1-1981, Requirements for Inservice Performance Testing of Nuclear Power Plant Pressure Relief Devices, for the test f r equency and test method.
ANSl/ASMC OH-1-1981, Section 7.3, Petlodic Testing, requires that no maintenance, adjustment, disassembly or othet activi g which could affect the "as found" set pressure ot-seat tightness data be permitted en safety relief valves prior to testing and that a
minimum of tvei. y percent of each such valve type and manufacture be tested within any twenty-four months.
Pr esently at the Davis-Besse lluelear Pover Station Unit Number 1 (DBNPS), the pressuriter code safety relief valves (RCl3A and RCl30) are experiencing minot seal leakage during normal plant opetating cycles.
Since the necessary equipment for testing the pressurizer code safety relief valves at the ambient temperatures or inlet pressures for the operating environment is not available at the DBNPS, the valves must be sent to an offsite vendor.
In order to meet the requirements of ASME B&PV Code Section XI, IVV-3510 for periodic testing, the pressurizer code safety relief valves vould need to be sent to the vendor's test facilities for the "as found" test, teturned to the site to be rebuilt and then returned to the vendor for final set piessure determination.
The "as found" testing tequirement vould result in these contaminated valves being shipped offsite tvice, and vould involve additional radiation exposure and cost, and also increase the potential for the spread of contamination.
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Docket Number 50-346 License Number NPl43 l
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i As an alternative, Toledo Odison proposes replacing the installed ptessurizer code safety relief valves during teiueling with replacement ptetested valves.
The removed pressurizer code safety relief valves vould be disassembled, repaired, and adjusted as required to limit seat leakage at the DBNPS.
This work would be periormed to approved procedures by qualifled maintenance individuals.
The DIINPS Repair and Replacement Program fully complies with the tequirements of Section XI of the ASHC Bl.PV Code and the National Board R, NR, and VR Program requitements.
The pressurizer code i.
safety relief valves vould then be shipped to an offsite vendor for final testing.
The valves vould be totuined to the DilNPS for statage until installation during future outages.
Toledo Edison considers this an nlternative method which provides an adequate level of quality and safety, while reducing potential contamination and ladiation doses.
Details of the tequested relief and proposed alternative are provided in the attachment of this lettet.
i This proposed alternative is submitted pursuant to 10CTR50.55a (a)(3) and
_(g)(5)(lii).
Toledo Edison requests that the NRC approve this proposed alternative by November 1, 1991.
L Should you have any questions regarding this request, please contact Mr. R. V. Schraudet, Manager - Nuclear Licensing, at (419) 249-2366.
Very
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,Qpv 5 KAS/ach attachment P. H. Ilyron, WRC Region III, DB-1 NRC Senior Resident Inspector
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r cci A. B. Davis, Regional Administrator, NRC Region III J. B. Ilopkins, NRC/NRR DB-1 Senior Project Manager
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J. H. Ilannon, Director, NRC Project Directorate Y11-3 Utility Radiological Saf ety 130ard l
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i Docket Number 50-346 License Number NPF-3 Serial Number 1936 Attachment Page 1 RELIEF REQUEST RV-4 SYSTEM REACTOR COOLANT VALVE (s):
RCl3A RCl3D CATEGORY:
C a
CLASS:
1 FUNCTION:
Pressurizer Code Safety Relief Valves ASME B&PV CODE, 1986 EDITION SECTION XI TEST REQUIREMENTS:
TVV-3510. Sifety Valves and Relief Valve Tests, references ASHE/ ANSI i
OH-1-1981, Requirements for Inservice Performance Testing of Nuclent Power Plant Pressure Relief Devices, Section 7.3, Periodic Testing, which states
...No maintenance, adjustment, disassembly, or other activity which.could affect "as found" set pressure or seat tightness data is permitted prior to 1
testing..."
OH-1-1981 also states that a minimum of 20 percent of each such valve type and manufacture vill be tected within any 24 months.
L BASIS FOR RELIEF:
Pressurizer code safety relief valves are developing minor seal leakage during normal plant operating cycles.
Since these valves are known to require repair, no "as found" tests vill be performed.
The Davis-Besse Nuclear Power Station (DBNPS) does not have the proper test equipment for testing at the ambient temperatures or inlet pressures for the operating
. environment. Therefore,_to meet the_0H-1-1981 requirements these valves vould have to be shipped to the vendor test facilities for "as found" testing and then after being rebuilt at the DBNPS shipped again to the vendor for final set pressute determination. This excessive shipping would increase the potential for both' contamination and radiation doses.
ALTERNATIVE TESTING:
l Every refueling, installed pressurizer code safety relief valves shall be replaced with pretested replacement valves. The removed code safety relief j
valves vill be disassembled, repaired and adjusted as required to limit seat I-leakage, or other identified repair by approved National Board R, NR, and VR' Program requirements.
During disassembly, a visual inspection vill be performed per maintenance procedure.
The pressurizer code safety relief valves vill then be shipped.to a vendor for final testing. The final set pressure determination vill be made and the valve sealed. The code safety relief valves vill be returned to storage at the DBNPS until installation during future outages.
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