ML20076J980

Forwards Util Requests for Relief from ASME Section XI Inservice Testing Program Requirements for Check Valves. Nature of Relief,Justifications &/Or Alternate Testing Provided for Each Request.Related Correspondence

ML20076J980
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/01/1983
From:	Flanagan D HUNTON & WILLIAMS
To:	Brenner L, Carpenter J, Morris P Atomic Safety and Licensing Board Panel
References
NUDOCS 8307070192
Download: ML20076J980 (24)

Text

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Hu x r ox & WILLI AM S . ,gCB 7o7 East MAIN STREET P. o. Box 1535p. . : - ' ' " ' ~

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July 1, 1983 Fac o.24566.000003 e...e,....o, o..ce7 o 6 ao. .o.

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I Lawrence Brenner, Esq. Dr. James H. Carpenter Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing ,

l Board Panel Board Panel .-p - / f ' ' ,x l U.S. Nuclear Regulatory U.S. Nuclear Regul Commission Commission d# -

Washington, D.C. 20555 Washington, D ., ,.

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Dr. Peter A. Morris J(J[' 40 Qlj

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Administrative Judge /c G83 > Z -

Atomic Safety and Licensing }A ome, en,.,

Board Panel  % \ C. issQ?ak i U.S. Nuclear Regulatory Commission ' ,@

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I Washington, D.C. 20555 Gentlemen:

4 The "Suffolk County Reply to LILCO and NRC Staff Sub-i missions on SC Contention 11," dated June 20, 1983, included an i affidavit of Dale G. Bridenbaugh. In paragraph 1 of his affi-t davit, Mr. Bridenbaugh discusses the relief requests for vari-

ous check valves in Shoreham's In-service Testing Program.

! Should the Board be interested in the nature of the relief re-

{ quests, the : justifications, or in alternative testing that may be conducted for the check valves (e.g., under Appendix J

! of 10 CFR Part 50, or under Shoreham technical specifications),

this information is provided in the relief requests. These re-

! quests have been previously submit'ted to the Board and parties

in SNRC-857 (April 15, 1983). Ecr the convenience of the Board, the relief requests for all the check valves in Shoreham's IST program are attached.

l Sincerely, Cu O . 9 b s4.gc % ( g

[ 271/869 Daniel O. Flanagan Attachments 1

cc: All Parties ,

! C307070192 830701 l PDR ADOCK 05000,3,,2 i T503

my DOCUMENT NO. 80A2903 Rev 2 11 "

NUCLEAR ENERGY SERVICES. INC. PAGE III-2-4 OF III-2-4 RELIEF REQUEST' RR - 1 System: Feedwater Valve: 1103A,B Category: AC Class: 1 Function: Containment isolation simple check valve (reverse flow closure for-containment isolation only).

ASME Section XI Quarterty Test Requirements: Verify reverse flow closure. >

Basis for Relief: The only method available to verify reverse flow closure is by valve leak testing during Appendix J, TYPE C testing at refueling.

AttemateTesting: Reverse flow closure will be verified during Appendix J Type C testing at refueling.

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, DOCUMENT NO. 80A2903 Rev 2 PAGE III-3-5 OF III-3-5 NUCLEAR ENERGY SERVICES. INC.

c REUEF REQUEST' RR - 1 System: Reactor Water Recirculation Valve: 0002A,B Category: AC Class: 2

, Function: Containment isolation simple check valv; (reverse flow closure for contair. ment isolation only) . -

ASME Section XI Quarterly Test Requirements: verify reverse flow closure.

C Basis for Relief: The only method available to verify reverse flow closure is by valve leak testing during Appendix J, "ype C testing at refueling.

Alternate Testing:

Reverse flow closure will be verified during Appendix J, Type C

• testing at refueling.

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• Fonu o NES 24412/82

80A2903 Rev 2 ,

DOCUMENT NO.

PAGE III-4-5 op III-4-8 NUCLEAR ENERGY SERVICES, INC.

RELIEF REQUEST' RR 1 1

1 System: Control Rod Drive Wlve: 1028A,B Category: AC Chu: 2 Function: Containment isolation simple check valve (reverse flow closure for containment isolation only).

ASME Section XI Quarterly Test Requirements: verify reverse flow closure.

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Basis for Relief: The only method available to verify reverse flow closure is by valve leak testing during Appendix J, Type C testing at refueling.

Alternate Testing: Reverse flow closure vill be verified during Appendix J, Type C

' testing at refueling.

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FoRW e NES 24612/82

- DOCUMENT NO. 80A2903 Rev 2 NUCLEAR ENERGY SERVICES. INC. PAGE III-4-6 op III-4_g C

RELIEF REQUEST' RR 2 System: Control Rod Drive Valve: AOV-126 : AOV-127 : HCU-ll4 (To be done for all 137 HCU's)

Category:

B (AOV-126 : AOV-127) -

C (HCU-ll4)

Chu: 2 Function: Reactor shutdown.

ASME Section XI Quarterty Test Requirements: Exercise, time and fail (ACV-126 : ACV-127).

Verify forward flow operability (HCU-114).

Basis for Relief: Individual valve testing is not possible without causing a control rod scram with a resulting change in core reactivity. Quarterly testing of these valves would violate plant Technical Specifi-cations which govern the methods and frequency of reactivity changes. The Technical Specification Control Rod Scram Insertion Time testing meets'the intent of Section XI testing requirements.

Alternate Testing: Tech. Spec. Control Rod Scram Insertion Time testing serves to

- verify proper operation of each of these valves. To be performed on 10% of the HCU's each 120 days; on each individual control rod after any maintenance or modification to that rod or system is performed which would affect tae scram insertion time for this rod; for all rods prior to thermal power exceeding 40% of rated thermal power following core alterations or after a reactor shutdown that is greater than 120 days.

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FomM o NES-24812/02

m DOCUMENT NO. 80A2903 Fev 2

" " " NUCLEAR ENERGY SERVICES, INC. PAGE III-4-7 OF III-4-8 l

( RELIEF REQUEST' RR 3 System: Control Rod Drive Valve: HCU-ll5 (To be done for all 137 HCU's)

Category:

C Chu: 2 Function: Reactor Shutdown.

ASME Section XI Quarterty Test Requirements: Verify reverse flow closure.

Basis for Relief: Verification of reverse flow closure requires securing the CRD pumps, depressuriring the header and monitoring the individual accumulator pressure and alarm to verify that the valves have closed on reverse flow. To de this requires entry into a high radiation work area and could also result in a plant scram.

Alternate Testing: Verification of reverse flow closure will be performed at

' refueling when the header can be depressurized without a possible plant scram and when area radiation is sufficiently reduced to allow extend entry for testing. Testing will be by depressurizing the header and monitoring the individual accumulator pressure and alarm to verify that the valves have closed on reverse flow. This test if required by plant Tech. Spec. Surveillance Requirement 4.1.3.5.

FORM e NES-24412/82

DOCUMENT NO. 80A2903 Fev 2 PAGE III-4-8 op III-4-8 NUCLEAR ENERGY SERVICES. INC.

c REUEF REQUEST' RR - 4 System:

Control Rod Drive Valve: HCU-138 (To be done for all 137 HCU's)

Category: C .

Class: 2 Function: Reactor shutdown.

ASME Section XI Quarterly Test Requirements: verify reverse flow closure.

( Basis for Relief: Individual valve testing is not possible without causing a control rod scram with a resulting change in core reactivity. Quarterly testing of these valves would violate plant Technicel Specifi-cations which govern the methods and frequency of reactivity changes. The Technical Specification Control Rod Scram Insertion Time Testing meets the intent of Section XI testing requirements.

Alternate Testing: verification of reverse flow closure will be performed in conjunction with the Control Rod Scram Insertion Time Testing by observing the control rod cooling line pressure and flow indications. In addition the cooling water header relief valve will be monitored during the test. This test method is currently being analyzed to determine if it meets the intention of Section XI. If it does not, an alternate test method will be developed and implemented by the first plant refueling outage.

FORM e NES-24612/s2

DOCUMENT NO. 80A2903 Rev 2 11

• NUCLEAR ENERGY SERVICES. INC. PAGE III-5-4 OF III-5-5 REUEF REQUEST' RR 1 System: Standby Liquid Control Valve: ocog : 0010 Category: AC -

Chu: 1 Function: SBLC injection line check valves.

ASME Section XI Quarterly Test Requirements: verify forward flow operability.

( Basis for Relief: To verify forward flow ope. ability during normal operation would require firing a squib valve and injecting water into the reactor vessel using the SBLC pumps. Injecting water during operation could result in adverse plant conditions such as changes in reactivity, power transiente, thermal shock induced cracking and a possible plant trip.

Alternate Testing: verify forward flow operability during refueling during the standby liquid control system injection test, which fires at least one squib valve and pumps demineralized water into the reactor vessel.

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l FORM e NES-24412/82

l Juur DOCUMENT NO. 80A2903 -Rev 2 11 " NUCLEAR ENERGY SERVICES, INC. E h OF EM RELIEF REQUEST' RR - 2 System:

Standby Liquid Control Valve: 0008 : 0010 Category: AC -

Class: 2 Function:

Containment isolation simple check valve (reverse flow closure for, containment isolation only).

ASME Section XI Quarterly Test Requirements: verify reverse flow closure.

Basis for Relief: The only method available to verify reverse flow closure is by valve leak testing during Appendix J, Type C testing at refueling.

Alternate Testing:

Reverse flow closure will be verified during Appendix J, Type C testing at refueling.

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ioAW e NES-24612/82

DOCUMENT NO. 03 .Rev 3 i

NUCLEAR ENERGY SERVICES. INC. NE III-ll-8 OF III-ll-12 b RELIEF REQUEST' RR - 1 System: upCI ~

Valve:

0022 Category: AC -

Chu: 2 Function: Containment isolation simple check valve (reverse flow closure for containment isolation only).

ASME Section XI Quarterty Test Requirements: Verify reverse flow closure.

Basis for Relief: The only method available to verify reverse flow closure is by valve leak testing during Appendix J, Type C testing at refueling.

Afternate Testing:

Reverse flow closure will be verified during Appendix J, Type C testing at refueling.

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Fomu o NES-24412/82

DOCUMENT NO. 80A2903 Rev 3 sm  !

NUCLEAR ENERGY SERVICES. INC. PAGE III-9-7 OF TTT o-7 RELIEF REQUEST' RR - 2 System: Core Spray Valve: 0018A,B Category: C Class: 2 Function: Loop level injection line check valves to core spray system.

ASME Section XI Quarterly Test Requirements: Verify reverse flow closure.

) Basis for Relief: Icop level piping configuration precludes verification of reverse flow closure.

Alternate Testiitg: Design changes are presently under consideration to either modify the loop- level piping configuration or to modify the valves to provide a means of. valve reverse flow closure verification. An

~

appropriete modification (s) will be selected and completed during the first refueling outage. During the interim forward flow operatility will be verified by a system check to verify system water inventory, t

( 0 l FORM e NES-24612/82

80A2903 pey 3 l DOCUMENT NO. l NUCLEAR ENERGY SERVICES, INC. NE III-ll-10 op III-11-12 REUEF REQUEST' RR 3 System: HPCI Valve: 0002 Category: C Class: 2 Function: Suppression pool suction line to pump check valve.

i l ASME Section XI l Quarterly Test Requirements: Full flow forward flow exercise.

Basis.for Aoiief:

The only possible full flow test would require pumping suppression pool water to either the a) feedwater system or b) condensate i

. storage tank. The first is precluded by the poor quality of pool water and possible thermal shock induced pipe cracking problems

' 'and the second by condensate tank water quality problems that would result from introducing pool water into the storage tank.

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Either method would also require extensive flushing of the system after testing which would over burden the radwaste system. The l

valve can be partial stroke exercised by injecting demin. water at the upstream test tap and verifying partial valve opening at the downstream test tap.

Afternate Testing:

A design change is presently under investigation to modify the valve by adding mechanical exercising feature that would provide full stroke test capability. If valve modification'is possible the valve will be modified during the first refueling and a full exercise test performed quarterly. During th.e interim.the vhlve will be partial stroke exercised quarterly using demin. water.

O FORM s NEs-24612/82

DOCUMENT NO. 80A2903 Rev 3 NUCLEAR ENERGY SERVICES. INC. PAGE III-ll-ll OF III-ll-12 A REUEF REQUEST RR - 4 System:

HPCI ~

Valve: 0023 : 0024 Category: C Clasc: 2 Function: Vacuum breakers (forward flow) to preclude drawing water into the turbine exhaust line and to prevent steam (reverse flow closure) flow to the suppression pool air space.

ASME Section XI Quarterty Test Requirements:

Verify forward flow operability and reverse flow closure.

(

Basis for Relief:

The system design has no test provisions to allow for quarterly testing in either direction. The only method available to verify

- operability is by using a test similar to the Appendix J, T.ype C test. This' test will be devised to verify both' forward flow opening and reverse flow closure and will be performed at refueling.

Afternate Testing:

A special test procedure similar to the Appendix J, Type C test procedure will be used to verify forward flow operability and reverse flow closure at refueling."

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FOMM e NES-24412/82

AEF DOCUMENT NO. 80A2903 Rev 3 PAGE I11-11-12 OFIII-ll-12 NUCLEAR ENERGY SERVICES. INC.

C RELIEF REQUEST' RR - 5 System: HPCI Valve: 0019 Category: C Class: 2 Function: Ioop level injection line check valve to HPCI system.

ASME Section XI Quarterty Test Requirements: verify reverse flow closure.

Basis for Relief: Loop level piping configuration precludes. verification of reverse flow closure. To review reverse flow closure would require securing the, loop level pump and draining the loop level piping, operating the HPCI system and monitoring an upstream vent line for leakage. This method would require opening vent valves during system operation at operating pressure, which presents a potential for injury to plant personnel.

Alternate Testing:

Design changes .are presently under consideration to either modify

'the loop level piping configuration or to modify the valve to provide a means of valve reverse flow closure verification. An appropriate modification (s) will be selected and completed during the first refueling outage. During the interim forward flow operability will be verified by a system check to verify system water inventory.

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m DOCUMENT NO. 80A2903 Rev 2 l NUCLEAR ENERGY SERVICES. INC. PAGE III-12-8 op III-12_11 C

REUEF REQUEST RR - 1 System: RCIC Valve: 0021 : 0025 Category: AC Class: 2 Function: Containment isolation sirple check valve (reverse flow closure for containment isolation only).

l ASME Section XI l

Quarterfy Test Requirements: Verify reverse flow closure.

Basis for Relief: The only method available to verify reverse flow closure is by valve leak testing during Appendix J, Type C testing at refueling.

Alternate Testing:

Reverse flow closure will be verified during Appendix J, Type C testing at refueling.

e FORM e NES-24612/82

mmr DOCUMENT NO. 80A2903 Rev 2 NUCLEAR ENERGY SERVICES, INC. PAGE III-12-10 op III-12-11 C

RELIEF REQUEST RR - 3 System: RCIC Valve: 0002 Category:

C Class: 2 Function: Suppression pool suction line to pump check valve.

ASME Section XI Quarterty Test Requirements:

Full flow forward flow exercise.

Basis for Relief: The only possible full flow test would require pumping suppression pool water to either the a) feedwater system or b) condensate storage tank. The first is precluded by the poor quality of pool water and possible thermal shock induced pipe cracking problems and the second by condensate tank water quality problems that would result from introducing pool water into the storage tank.

Either method would also require extensive flushing of the system after testing which would over burden the radwaste system. The valve can be partial stroke exercised by injecting demin. water at the upstream test tap and verifying partial valve opening at the downstream test tap.

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Alternate Testing:

A design change is presently under investigation to modify the valve by adding a mechnical exercising feature that would provide full stroke test capability. If valve modification is possible the valve will be modified during the first refueling and a full exercise test performed quarterly. During the interim the valve will be partial stroke exercised quarterly using demin, water.

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, ronu e wts-24s 12/s2

l mr DOCUMENT NO. 80A2903 Rev 2 NUCLEAR ENERGY SERVICES. INC, PAGE 111-12-11 OF I11-12-11 RELIEF REQUEST RR - 4 System: RCIC Valve: 0022 : 0023 Category: C Class: 2 Function:

Vacuum breakers (forward flow) to preclude drawing water into the~

turbine exhaust line and to prevent steam (reverse flow closure) flow to the suppression pool air space.

ASME Section XI Quarterly Test Requirements:

( verify forward flow operability and reverse flow closure.

Basis for Relief:

The system desien has no test provisions to allow for quarterly testing in either direction. The only method available to verify operability is by using a test similar to the Appendix J, Type C test. This test will.be devised to verify both forward flow opening and reverse flow closure and will be performed at refueling.

Alternate Testing:

. A special test procedure similar to the Appendix J, Type C test procedure will be used to verify forward flow operability and reverse flow closure at refueling.

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FORM e NES-24412/82

DOCUMENT NO. 80A2903 pov 2 NUCLEAR ENERGY SERVICES, INC. PAGE III-13-3 op III-13-4 C

REUEF REQUEST RR 1 System: Radwaste Valve: 2110C Category: AC Chu: 2 Function: Containment isolation simple check valve (reverse flow closure for containment isolation only).

ASME Section XI Quarterty Test Requirements: Verify reverse flow closure.

I Basis for Relief:

The only method available to verify reverse flow closure is by valve leak testing during Appendix J, Type C testing at refueling.

AlternateTesting: . Reverse flow closure will be verified during Appendix J, Type C testing at refueling.

i i Fomu o NES-24412/82

muy DOCUMENT NO. 80A2903 Rev 2 NUCLEAR ENERGY SERVICES. INC. PAGE III-13-4 og III-13-4 REUEF REQUEST l

RR - 2 I

System: Radwaste Valve: 2110C Category:

AC Class: 2 Function:

Lenkage returr pump discharge line containment isolation valve.

ASME Section XI Quarterty Test Requirements:

Verify forward flow operability.

Basis for Relief:

To verify forward flow operability would require pumping water from the floor drain sump into the suppression pool. Typically water pumped from the sump is of relative poor quality. Injection of this poor quality water into the suppression pool would result in water quality control problems. This would be a plant operating problem during normal operation and cold shutdown when the suppression pool water is maintained relatively clean. It would have much less impact on operations at refueling when pool water quality tends to drop.

Alternate Testing:

verify forward flow operability at refueling.

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FORM e NES 24612/32

- DOCUMENT NO.

80A2903 Rev 2 NUCLEAR ENERGY SERVICES. INC. PAGE III-14-3 OF III-14-3 C

RELIEF REQUEST RR- 1 System:

Reactor Water Cleanup Valve: 0036A,B : 0050A,B Category: C Class: 1 Function: System isolation ASME Section XI Quarterly Test Requirements:

Verify reverse flow closure.

Basis for Relief:

Valves are located in the main steam tunnel which is inaccessible during normal plant operation or cold shutdown. In addition, interruption of normal RWCU letdown flow during, normal operation or cold shutdown could cause serious reactor water chemistry problems.

Alternate Testing:

. Reverse flow closure will be verified at refueling when ent1'1 to the main steam tunnel is possible.

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ar OOCUMENT NO. 80A2903 Fev 2 NUCLEAR ENERGY SERVICES, INC. PAGE III-18-16 OF III-18-16 C

REUEF REQUEST RR - 1 System: RBOLC.1 Valve: 0037 AA,AB,AC,AD,BA,BB,BC,BD Category: AC Class: 2 Function: Containment isolation simple check valve (reverse flow closure for containment isolation only).

ASME Section XI -

Quarterly Test Requirements: Verify reverse flow closure.

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Basis for Relief: The only method available to verify reverse flow closure is by valve leak testing during Appendix J, Type C testing at refueling.

Alternate Testing: Reverse flow closure will be verified during Appendix J, Type C testing at refueling.

FORM # NEs 24612/12 l

mr DOCUMENT NO. 80A2903 Psv 2

" " " III-19-5 NUCLEAR ENERGY SERVICES, INC. PAGE OF III-19-5 REUEF REQUEST RR - 1 System:

Instrument and service Air Valve:

0695A,B : 0603 : 0811 : 0821 : 1C51-0867 Category: AC Class: 2 Function:

Containment isolation signple check valve (reverse flow closure for containment isolation only).

ASME Section XI Quarterly Test Requirements:

verify reverse flow closure.

k Basis for Relief:

The only method available to verify reverse flow closure is by valve leak testing during Appendix J, Type C testing at refuelinc.

Attemate Testing:

Reverse flow closure will be verified during Appendix J, 'Iype C testing at refueling.

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FOmu o NEs-24612/82

, DOCUMENT NO. 80A2903 Rev 3 1 = NUCLEAR ENERGY SERVICES, INC. 1%GE III-24-9 OF III-24-12._b i

(' RELIEF REQUEST '

RR - 1 System: Primary Containment Atmospheric Control .

Wive: OOl6A,B Category: AC Class: 2 Function: Containment isolation simple check valve (reverse flow closure for containment isolation only) .

ASME Section XI Quarterly Test Requirements: Verify reverse flow closure.

Basis for Relief: The only method available to verify reverse flow closure is by valve leak testing during Apper. dix J, Oype C testing at refueling.

Alternate Testing:

Reverse flow c1soure will be verified during Appendix J, Type C testing at refueling.

I Fonu o Nts-24612/82

r-DOCUMENT NO. 80A2903 Rev 3

" " " NUCLEAR ENERGY SERVICES, INC. PAGE TTT-24-lQ. _ OF TTT-24-12 d RELIEF REQUEST '

RR - 2 System: Primary Containment Atmospheric Control Valve: 0004A,B Category: C Class: 2 Function: Hydrogen recombiner outlet check valves.

ASME Section XI Quarterly Test Requirements: Exercise Basis for Relief: The only way to verify full flow opening is during the hydrogen recombiner functional test which is perfortned by Technical Specification Surveillance Requirements 4.6.6.1.which test the hydrogen re' combiners for operability at least once every six months.

Alternate Testing:

Verify operability during hydrogen recombiner functional testing at least once every six months.

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l FOpW e NES 24612/82