ML20086T689
| ML20086T689 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/30/1991 |
| From: | Woodard J SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9201070023 | |
| Download: ML20086T689 (18) | |
Text
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U. S. Nuclear Regulatory Comission ATilh Document Control Desk Washington, DC 20555 Joseph H. f arley Nuclear Plant - Unit 2 Inservice Testing Program for ASME Code Class 1, 2 and 3 BLmplandlalyff - PtgutsLfpr Relief from Imntglical RLquirementi Gentlemen:
By letter dated May 23, 139;, the NRC transmitted its Safety Evaluation /
Technical Evaluation Report (SE/TER) for the subject inservice Testing (IST) Program.
The SE/TER denied portions of two relief requests and interimly granted four relief requests where it is impractical for Southern Nuclear Operating Company to comply with the schedular and/or technical requirements imposed by the SE/TER.
By letter dated Dncember 3, 1991, these relief requests were identified, a brief description of the impracticality of the imposed requirements was provided and a meeting was requested with the NRC staff to discuss these issues.
At a result of this December 16, 1991 meeting, Southern Nuclear Operating Company herewith submits six revised relief requests which have been t
l rewritten to reflect these discussions with the NRC staff Two additional relief requests have also been revised to incorporate generic wording from the SE/TER, as discussed in the meeting.
These two relief requests replace those originally submitted by letter dated July 29, 1991 and were not addressed in the SE/TER.
The third relief request (Q2E21-RV-15) ar.d l
additional information provided in the July 29, 1991 letter remain unchanged and still require NRC review, in addition to the items discussed in the meeting, the SE/TER granted a relief request to backflow test three Unit 2 Component Cooling Water system check valves.
This relief request has been revised to permit en improved method of measuring backflow leakage.
One revised cold shutdown justification is being submitted for information purposes.
This cold shutdown justification, which was previously submitted to the NRC, has been revised to clarify which Auxiliary feedwater System valves can be partial flow tested on a quarterly basis and to indicate the proper Code classification for each valve, Attachment I contains the revised relief requests, cold shutdown justification and a summary explaining the changes made to each as discussed above. lists the relief requests which were granted in the SE/TER and no further action is required; the provisionally granted relief requests whera the relief requests will be modified and implemented in accordance with tne "E/TER and are considered to be graated with no
'4 further action required; and, the relief requests which were withdrawn or have been subsequently deleted.
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ll. S. Nuclear Regulatory Commission Page two As discussed in the meeting and in the December 3, 1991 letter, Southern Nuclear Operating Company is proceeding with revising the IST Program and procedures and will place these into effect no later than March 3, 1992 assuming that the NRC interimly grants the remaining ten relief requests (nine relief requests included in Attachment 1 plus relief request 02E21-RV-15 from the July 29, 1991 Ictter) by February 28, 1992.
It is Southern Nuclear Operating Company's understanding that this interio granting will remain in effect until the NRC issues its final SE/TER.
In addition to the resolution of relief r9 quest issues, the NRC recuested that information be supplied regarding actions taken, if any, to acdress a potential issue concerning the need to reverse flow test the check valve in the High Head Safety injection Pump suction line from the Refueling Water Storage Tank.
This concern was identified in NRC Information Notico (IN)91-56.
Design reviews conducted during the IST Program update determined that this check valve does not perform a safety-related function in the reverse flow direction; therefore, current IST Program and associated procedures do nK require reverse flow closure testing this check valvo.
Evaluation ci the IN has begun and will include a review and determination of the adequacy of existing IST practices, if there are any questions or if additional information is required, please advise.
Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY bb.wh_k (J.l}Woodard JDW/ STB: map If76 cc: Mr. S. D. Ebneter Mr. S. T. Hoffman Mr. G. f. Maxwell
ATTACHMENT 1
SUMMARY
Of ENCLOSED RELIEF REQUESTS TO THE JOSEPH M. FARLEY NUCLEAR PLANT - UNIT 2 INSERVICE TESTING PROGRAM FOR ASME CODE CLASS 1, 2 AND 3 PUMPS AND VALVES PR-10 lhis relief request has been revised to provide additional clarification in the *0 asis for Relief" and " Alternate Testing" sections for the dual pump testing method utilized at FNP.
These changes were discussed during the NRC meeting of December 16, 1991.
Q2B13-RV-1 This relief request was revised to reflect modifications performed which routed the heat vent discharge piping to the PRT, to clarify the " Basis for Relief" section to be more representative of how the valves actually function, to strengthen the justification for not testing at RCS pressures greater than 100 psig.
Q2E13-RV-1 This relief request has been revised to indicate that FNP intends to implement plant modifications which will facilitate full flow testing of these valves in conjunction with pump testing at refueling.
However, the modifications cannot be implemented any earlier than the 10th refueling outage.
Therefore the initial relief request was revised to add partial flow testing with air af ter reassembly and a new relief request was developed for testing after the modifications are completed.
Therefore, two versions of this relief request are included and each contains a note which describes its applicable time period.
Q2E21-RV-1 This relief request has been revised to provide additional justification for not part stroke exercisina this valve quarterly or at cold shutdown.
The alternate test proposed was also changed to reflect full flow testing during refueling.
Q2E21-RV-4 This relief request has been revised to include all SI check valves and to indicate that flow instrumentation does not exisM therefore, full flow exercising is not possible. A requirement to partia stroke test with flow after reassembly was also added.
Note that relief requests Q2E21-RV-6 and Q2E21-RV-10 have been deleted since the above listed relief request now covers all of the subject valves and all aspects of the previous relief requests.
Q2N23-RV-1 This relief request has been revised to propose an alternate method of proving check valve closure.
Q2P17-RV-3 This relief request has been editorially revised to permit an improved methoc of performing reverse flow closure testing.
Q2P19-RV-2 This relief request was submitted to the NRC by letter dated July 29, 1991 for the Unit 2 IST Program and was not included in the SE/TER.
Editorial changes were made based on the SE/TER to clarify the
" Basis for Relief."
Q2P13-RV-3 This relief request was subn.itted to the NRC by letter dated July 29, 1991 for the Unit 2 IST Program and was not included in the SE/TER.
Editorial changes were made based on the SE/TER to clarify the
" Basis for Relief "
t
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Q2N23-CS-1 This cold shutdown justification was revised to correct the ASME Coac Class of the valves involved and to clarify which valves can be partial stroke exercised quarterly, i
l FNP 2 MOO 7 PUMP REUEF REQUEST PR 10 Systom:
Servico Water l
Pump:
P001 A-A, P001B-A, P001C-AB, P0010-B, P001E B Class:
3 Function:
Provide cooling water to safoty-related equipment.
Test Roqultomont:
IWP-3400(a) requires that an inservice test be run on orch pump.
Basis 'or Relief:
The Servico Water System is designed so that durtn; normal operation there are two pumps in each of the two trains operating, with a standby pump available to swing to either train.
Each pump has pressuto gages, however flow instrumentation is installed only to measure the tow from each of the two truins.
Oloco flow instrumentation was not provided auring construction for each pump, the only viable means of IndMdually testing these pumps is by removal of one pump from service and measuring flow through the train with only one pump aligned. However, a flow of 32,100 gpm, which requires four pumps (or both trains operable) is required for normal operatio, per the FSAR. A condition whero only one pump is aligned at a timo to a train would result in degraded cooling water flow to essential or safety related equipment and is therefore an unacceptable method of operation. Furthermore, removal of one pump from the service water train could lead to an isolation of the turbino building service water supply lines causing a plant trip.
Since hydraulic performanco of a degrading pump may be inaskod by the other pump when service water pumps are testod in pairs FNP has developed analytical
- methods which can be used to datormine individual pump flow rate. These analytical methods involvo solving three equations involving dual pump flows for three Individual pump flow rates. These analytical methods have proven rollable in determining individual pump degradation when the other pump in combination is compensating for the degradod pump.
Alternato Testing:
Quarterly combined flow, inlet pressure, differential pressure and vibration will be measured and compared to reference valuos. IndMdual pump evaluations, which consist of performing three-two pump combination tests at a reference differential pressure and solving analytical equations for individual flows, will be performed whenever combined flow measurements are not in the acceptable range and throo pumps are available to support the testing, Correctivo action will be taken on tho
-indMdual pumps ss a result of the evaluation in accordance with IWP 3230.
12-31 91
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FNP 2 M 007 RELIEC REQUES1 t
l 02B13 HV 1 I.
System:
Reactor Coolant Valve:
Category:
B Class:
2 Function:
Valves open to vont the reactor vossol.
I ASME Section XI Test Requirements:
Exorcise, time and fall quartoriy, (IVN 3411,3413 and 3415)
Remote position Indicatiort (IWV 3300)
Basis for Rollof:
The head vont valves can not be exercisod during normal operation with adequato assurance that an uncontrolled release of reactor coolant and a rapid RCS de-pressurization would not occur. To exerciso the valves open in any order could result in a potential pressure shock to the closed valve and a potentlal ' BURP' teaction. The consequences of this reaction are too sovero to warrant testing during normal operation.
The RPV head vont valves are Target Rock solenoid operated valvos. The valvo stem is complotoly enclosed within the operator and thus visual position verification is impossible. Position Indicators (rood switchot.) are located within the operator and provide posillon Indication for the pilot valvo assembly, in order to verify that the valves exerciso open and re close and agroo with remote indication, it is necessary to establish flow through the vont linos. Flow cannot be establishod through the vont lines except at refueling or cold shutdown when plant conditions for testing can be established. To insure that a stuck open valve would not causo an uncontrollable loss of reactor coolant and rapid do-pressurization it is proforable i
that RCS pressure be less than 100 psig.
Attomato Testing:
Those valvos will be full stroke exercised, timod and fall safe tostod and the head vent floN path veriflod operable at refueling or at least every la months as required by the Plant Technical Specifications. In addition, those valves will be exercisod at cold shutdown jf RCS pressure is less than 100 psig.
7 l
l; 124291
FNP 2-M407 l'EUEF REQUEST O2E13 RV 1 1
System:
Containment Spray Valve:
OV002A, OV002B Category:
C j
Class:
2 Function:
Containment spray system insido containment isolation check valvos (OV002A, B).
ASME Section XI Quarterly Test Requirements:
Verify forward-flow operability. (liW-3521)
Basis tur Rollef; The only way to verify forward flow operability during normal oporation or cold shutdown would bo by using the pumps and injecting a largo quality of water into the containment. Spraying the containment would result in extensivo damage to safoty related equipment located int.ido the containment.
Alternato Testing:
One of these valves will be disassembled and manually full stroke tostod at each refueling on a staggered test basis. The valvo internals will be verified as structurally sound (no loose or cortodod parts) and the disk manually oxorcisod to verify full stroke capability. If the disassembled valvo !3 not capable of being dull-stroke exercisod or thero is binding or fallu o of valvo internals, the romalning valvo must also be disassembled, inspected, and manually full stroko exercisod during the same outago.
The disassembled valves will be part stroked with air flew after reassembly. Pow Indication wlli be through Installod instrumentation, observed pressure changes, lovel changes or through the use of ultrasonic l'or sitnitar) flow measuring devices.
Note: This relief request is applicable until the Unit 2 modification which supports full flow containment spray pump testing is implemented.
s l
12 31 91 l
FNP4M007 REUEF REQUES1
)
02E13 RV 1 System:
Containmont Spray l
Valve:
OV002A, OV0020 OV014 l
Category:
0 Class:
2 Function:
Containment spray syg tom insido containment isolation chock valvos (OV002A, B) and RWST to containment spray pump suction lino chock valvo (OV064).
ASME Section XI Ouartorly Test Roqulrements:
Verify forward fic / oporability. (IkW-3521)
Basis for Rollof:
The only way to verify forward-flow operability during normal oporation or cold shutdown would bo by M ig the pumps and Injocting a largo quality of water into the containment. Sprapng the containment would result in extensivo damage to safoty related equipment locatoJ insido the containment.
Attornato Testing:
The system has boon modified such that spool plocos can be installed downstream of those check valves. During refueling, those spool plocos will be installod and a full forward-flow test performod by pumping water through these full-flow test linos to the containment refueling cavity. Because of the timo involved in installing the spool pieces and the largo quantity of water necessary, this lost can only be performed at refueling. In addition. OV014 will be partial forward flow veriflod during quartorfy pump testing.
Note: This relief request is not applicable until the Unit 2 modification which supports full flow festing of the containment spray pumps is completed.
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A 12 31 91 1
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1 FNP 2 M 067 i
REllEF REQUEST t
02E21 RV 1 i
System:
SI/CVCS Valvo:
OV020 r
Category:
C Class:
2 Function:
RWST to charging pump suction lino check valvo.
ASME Section XI Test Roquiroments:
Verify forward flow operabillly quarterly or at cold shutdown. (lWV.3521)
Danis for Rollof:
The only post,1blo rnothod of full ficry testing this valvo is by aligning the RWST to the charging pump suction and injecting full design flow into the RCS, Full flow -
torting during normst operation is impossible because the charging pumps cannot develop full rated flow against ACS pressure.
Partial flow festing cannot be performed during normal operation becauso water from the RWST is highly borated and injection into the RCS could adversely affoct -
toactMty.
Full or partial flow testing at cold shutdown could only be periormed with a stoam bubblo in tite pressurizer to provent overpressure transtonts. Howevor, normal plant practice is to collapse the bubblo early lo the shutdown proceduto and cool the plant down in the solid condition, Thotofore, to full or partial flow test at cold shutdown would requito rnalntaining the pressutlior bubble for a 10ngor period of time which would postpono other related shutdown activities.
I Attornato Testing:
Design accident flow will be verlflod to be oassing through the valvo each refueling
. outago.
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FNP 2 M467 REUEF REQUEST 02E21 RV System;
_ Si/CVCS Valve:
Group 1 - QV062A, OV0628, QV062C Group 2 OV004A, QV000B, OV000C Group 3 OV078A, OV0788 OV078C Group 4 OV079A, OV079B, OV079C Category:
C Class:
1 Functic.n:
Safety injection to the RCS check valver ASME Section XI Test Requirements:-
Verify forward flow operability quarterly or at cold shutdown. (IVW 3521) t3 asis for Relief:
it is impractical to full or part stroke any of these check valves with flow during normal operation because all of the associated flow paths bypass the regenerative heat exchar067 and establishing flow through these valves would rt sult in relatively cold water being hjected into the RCS. The thermal stresses produced by injecting cold water could greatly reduce the service life of the injection nozzles. These valves cannot be full stroke exercised during cold shutdowns because the RCS may not contain sutticient expansion volume to accommodate the flow required and a low temperature overpressure condition could occur, it is also impractical to confirm a part stroke exercise of those valves during cold shutdowns because permarxnt flow instrumentation is not instailed for the individual flow orifices on tne system. The test connections at the orifices have been capped and seal welded. Use of these flow orifices would require a design chang' R the system.
Alternate Testing:
One of the va'ves from each three valve group will be disass6mbled and manually full stroke tested at panh refueling on a s',aggered test basis. The valve internals w':1 be verified e u:t> 'lly sound (no loose or corroded parts) and the disk manually exercuo te
- pul! stroke capability.- if the disassembled valve is not capable of being ruhy, A emcised or there is binding or failure of valve internals, the remaining valves in tne group must also be disassembled, inspected, and manually full-stroke exercised during the same outage..
The disassembled valves will be part stroked with flow after reassembly. Flow Indication will be through installed common header instrumentation, observed pressure changes, level changes or through the use of ultrasonic (or similar) flow measuring devices.
1b31-91 r
+ -, -
FNP 2-M 067 RELIEF REQUEST 02E21 RV-6 1
DELETED (See Rollef Request 02E21-RV-4) i t
i 12-31-91 l
FNP-2.M-067 REUEF REQUEST 02E21 RV 10 DELETED (Sco Relief Roquent 02E21-RV4) i l
12-31-91 l-l-
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4 FNP 2-M467 l
REUEF REQUEST O2N23 RV 1 System:
Auxillary Feedwater Valve:
OV006, QV007A, OV0078 Category:
C Class:
3 Function:
Condensate storage tank to auxiliary feedwater pump suction line check valves.
ASME Section XI Quarterly Test Requirements:
Verify reverse flow closure. (l)W-3521)
Basis for Rollef:
There are no system design provisions for verification of reverse flow closure. The only possible test method would involve isolating the condensate storage tank, draining a large section of piping, and injecting service water into the auxiliary feedwater system. The service water is of poor quality and would contaminate the auxillary feedwatar piping. It cannot be guaranteed that flushing will remove all contamination after testing, Any contaminants which remain in the pTing may be injected into the steam generators which could adversely affect secondary water chemistry and contribute to steam generator degradation.
Alternate Testing:
Reverse flow closure will be confirmed by a leak test, similar to arl Appendix J -
Type C Test, during each refueling outage.
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FNP 2 M-007 RELIEF REQUEST O2Pt7 RV-3 System:
Component Cooling Water Valve:
OV087A, OV087B, OV087C Category:
C Class:
3 Function:
These check va'/es will close to protect the low pressure component cooling water (CCW) piping frem RCP thermal barrier leakage.
ASME Section XI Quarterly Test Requirements:
Verify reverse-flow closure.(liW-3521)
Basis for Relief:
The only way to verify reverse flow closure of these valves requires isolating component cooling water flow to the Reactor Coolant Pumps, entering the containment and locally measuring backflow leakage Plant procedures strictly regulate entry into the containment during normal operation and at cold shutdown.
Attemate Testing:
During each refueling outaga component cooling water flow to the Reactor Coolant Pumps will be isolated and reverse flow closure will be verified by measuring backflow leakage.
i 12 31-91 1
9 FNP 2 Mo67 RELIEF REQUEST 02P19 RV 2 System:
Instrument Air Valve:
OV004 Category:
AC Class:
2 Function:
Backup nitrogen supply to pressurizer PORVs.
ASME Section XI Quarterly Test
-Requirements:
Verify forward flow operability quarterly or at cold shutdown (lWV 3521).
Basis for Relief:
There are no system design provisions for verification of forward flow operability and~ testing will require isolation and venting of the instrument air header.
Instrument air supplies a number of components inside containment which are necessary for normal operation. Testing during normal operation or at cold shutdown would deprive these components of their normal air supply, and since
- the system has no reserve air stora00 capacity, could result in operating transients or component failures. Loss of instrument air during normal operation could result in a forced plant shutdown.
Alternate Testing:
This valve will be forward-flow verified at each refueling when Instrument air can be isolated without causing loss of instruments and compcnonts necessary for plant operations.
12-31-91
4 FNP 2 M407 RELIEF REQUEST 02P19-RV 3 Systern:
Instrument Air Valve:
NV243, NV236A, NV2300 Category:
C Class:
NA Function:
Backup nitrogen supply to pressurizer PORVs.
ASME Section XI Quarterly Test Requirements:
Verify reverse flow closure. (IWV 3521)
Basis for Rollet:
Thom are no system design provisions for verification of reverse flow closure and testing will require isolation and venting of the instrument air header. Instrument air supplies a number of components inside containment which are necessary for normal operation. Testing during normal oporation or at cold shutdown would deprive those components of their normal air supply, and since the system has no reserve air storage capacity, could result in operating transients or component failures. Loss of instrument air during normal operation could result in a forced plant shutdown.
Alternate Testing:
One of thot,e valves will be disassemblod and manually full stroke tested at each refueling on a staggered test basis. The valve intomals will tr veriflod as structurally sound (no loose or corroded parts) and the disk manually eacrcised to verify full stroke capability, if the disassembled valve is not capable of being full stroke exercised or there is binding or falluto of valve internals, the remaining valves in that group must be disassembled, irt,, acted, and manually full stroke exercised during the same outago.
Tha disassembled valve will be part stroked with flow after roassembly, Flow indication will be through installed instrumentation, observed pressure changes, level changes or through the use of ultrasonic (or similar) flow measuring devices.
12-31 91
FNP 2-M467 COLD SHUTDOWN TEST JUSTIFICATION L
02N23 CS 1 '
System:
Auxillary Feodwater Valve:
OV002 (A through H), OV003, OV006 OV007A, OV0078, OV011A, QV0118, OV011C Category:
C Class:
3, 3 ASME Section XI Quartody Test Requirements:
Verify forward flow operability. (IWV 3521)
Cold Shutdown Test Justification:
The only way to verify full forward-flow operability of those valvos is by operating the auxlitary feedwater pumps and injecting relatively cold condensate water directly into the steam generators. The introduction of cold water into the hot steam generators during operation would result in largo thermal shock to the feodwater nonles and could cause cracking of the nonlos.
Quarterly Part Stroko Testing:
Valves OV006 and OV007A,B (AFW pump suction check valves) will be partial-forward-flow verified during pump testing.-
Cold Shutdown Testing:
Full-forward-flow operability will be verified by injecting into the steam generators at cold shutdown.
i-l 12-31 91
ATTACHMENT 2
SUMMARY
OF RELIEF REQUESTS TO THE JOSEPH M. FARLEY NUCLEAR PLANT - UNIT 2 INSERVICE TESTING PROGRAM FOR ASME CODE CLASS 1, 2 AND 3 PUMPS AND VALVES 1.
Per the NRC SE/TER, the below listed relief requests have been granted and no further action is required:
PR-1 Q2E13-RV-2 PR-2 Q2E14-RV-1 PR-5 Q2E21-RV-3 PR-9 Q2E21-RV-7 PR-12 02G21-RV-1 PR-17 Q2N23-RV-2 PR-18 Q2Pll-RV-1 VG-1 Q2P16-RV-2 VG-3 Q2Pl7-RV-2 VG-4 02Pl7-RV-3 02B13-RV-2 Q2P19-RV-1 Q2 Ell-RV-1 Q2R43-RV-1 2.
FNP will comply with the provisional requirements stated in the NRC SE/TER for the below listed relief requests by March 3, 1991:
PR-4 02E21-RV-5 PR-6 Q2E21-RV-8 PR-8 Q2E21-RV-9 PR-15 Q2E21-RV-ll PR-16 Q2E21-RV-13 PR-19 Q2E21-RV-14 Q2 Ell-RV-2 Q2N12-RV-1 Q2 Ell-RV-3 02P16-RV-1 Q2 Ell-RV-4 Q2P16-RV-3 02E13-RV-1 02P16-RV-4 Q2E13-RV-3 02F16-RV-5 Q2E13-RV-4 Q2Pl7-RV-1 Q2E21-RV-2 Q2Pl7-RV-4 3,
ine below listed relief requests have been or will be deleted from the IST Program:
VG-2 Deleted by letter dated July 20, 1989.
PR 7 Deleted by letter dated August 20, 1990.
PR-ll Deleted by letter dated August 20, 1990.
PR-18 Deleted by letter dated July 29, 1991 due to use of Code Case N-472.
Q2 Ell-RV-5 Incorporated into Q2E11-RV-3.
Q2 Ell-RV-6 The subject valves are not required to be tested per ASME XI and will be deleted from the program.
Q2E11-RV-7 Incorporated into Q2E11-RV-4.
02E13-RV-4 Will be deleted af ter the Unit 210th refueling Dutage.
Revision enclosed for NRC review.
Q2E21-RV-6 incorporated into Q2E21-RV-4.
Q2E21-RV-10 Incorporated into Q2E21-RV-4.
Q2E21-RV-11 Incorporated into 42E21-RV-14.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _