ML20086U028
| ML20086U028 | |
| 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 9201070171 | |
| Download: ML20086U028 (14) | |
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Ia%'y rtend Docket No. 50-348 10 CfR 50.55a(g)
U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555 Joseph M. farley Nuclear Plant - Unit 1 Inservice Testing Program for AStiE Code Class 1, 2 and 3 Pumps and Valves - Rigpest for Pelief frqm impractical Rtquirementi t
Gentlemen:
By letter dated May 23, 1991, the NRC transmitted its Safety Evaluation /
icchnical Evaluation Report (SE/TER) for the subject inservice Testing (ITS) Program.
The SE/TER denied portions of two relief requests and intertmly granted three 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 December 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.
As a result of this December 16, 1991 meeting, Southern Nuclear 0)erating Company herewith submiL five revised relief requests which have aeon rewritten to reflect these discussions with the NRC staf f.
Two additional relief requests have also been revised to incorporate generic wording from the SE/1ER, as discussed in the meeting.
These two relief requests replace those originally submitted by letter dated July 26, 1991 and were not addressed in the SE/TER.
The third relief request (QlE21-RV-15) and additional information provided in the July 26, 1991 letter remain unchangeJ and still require NRC review.
In addition to the issues discussed in the meeting, the SE/TER granted a relief request to disassemble three Unit 1 Component Cooling Water system check valves provided a partial flow test was performed following reassembly, for the same Unit 2 valves, the SE/TER granted, without provisions, a relief request utilizing a reverse flow closure test.
The Unit I relief request has been revised to require a reverse flow closure test similar to the relief granted for Unit 2.
The test method has been revised to permit an improved method of measuring backflow leakage.
One cold shutdown justification, which was previously submitted to the NRC for information purposes, 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. Attachment 2 lists the relief requests which were granted in the SE/TER and no further action is required; the provisionally granted relief requests where the relief requests will be modified and implemented
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g U. S. Nuclear Regulatory Commission Page two in accordance with the SE/TER and are considered to be granted with no further action required; and, the relief requests which were withdrawn or have been subsequently deleted.
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 3,1990 assuming that the NRC interimly grants the remaining nine relief requests (eight relief requests included in Attachment 1 plus relief request QlE21-RV-15 from the July 26, 1991 letter) by February 28, 1992.
It is Southern Nuclear Operating Comniry's understanding that this interim granting will remain in effect until the NRC issues its final SE/1ER.
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In addition to the resolution of relief request issues, the NRC requested i
that information be supplied regarding actions taken, if any, to address a potential issue concerning the need to reverse flow test the check valve in the High Head Safety injection Pump suction 1tne from the Refueling Water Storage Tank. This concern was identified in NRC Information Notice (lN) 91-56.
Design reviews conducted during the IST Program update determined that this valvo does not perform a safety function in the reverse flow direction; therefore, current IST Program and associated procedures do not require reverse flow closure testing this check valve.
Evaluation of 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 sulmitted, SOUTHERN NUCLEAR OPERATING COMPANY
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Wooifard JDW/ STB: map 1574 Attachments cc: Mr. S..D. Ebneter Mr. S. T. Hoffman Mr. G. F. Maxwell 1
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ATTACHMENT 1
SUMMARY
Of ENCLOSED REllEr REQUESTS TO THE JOSEPH M. FARLEY NUCLEAR PLANT - UNIT 1 INSERVICE TESTING PROGRAM FOR ASME CODE CLASS 1, 2 AND 3 PUMPS AND VALVES PR-10 This relief request has been revised to provide additional clarification in the " Basis for Relief" and " Alternate Testing" sections for the dual pump testing method utilized at F.1P.
These changes were discussed during the NRC meeting of Decemt:er 16, 1991.
Q1813-RV-1 This relief request was revised to reficct modifications performed which routed the head 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.
Q1E21-RV-1 This relief request has been revised to provide additional justification for not part stroke exercising this valve quarterly or at cold shutdown.
The alternate tvt proposed was also changed to reflect full flow testing during refueling.
Q1E21-RV-4 This relief request has been revised to include all Si check valves and to indicate that flow instrumentation does not exist; therefore, full-flow exercising is not possible.
A requirement to partial stroke test with flow after reassembly was also added.
Note that relief requests QlE21-RV-6 and QlE21-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.
Q1N23-RV-1 This relief request has been revised to propose an alternate method of proving check valve closure.
Q1P17-RV-3 This relief request has been revised to perform an improved method of reverse flow closure testing at each refueling outage.
This relief is now similar to Q2Pl7-RV-3 which was granted by the NRC in the SE/TER.
Q1P19-RV-2 This relief request was submitted to the NRC by letter dated July 26, 1991 for the Unit 1 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."
Q1P19-RV-3 This relief request was submitted to the NRC by letter dated July 26, 1991 for the Unit 1 IST Program and was not included in the SE/TER.
Editorial changes were made based on the SE/lER to clarify the -
" Basis for Relief."
Q1N23-CS-1 This cold shutdown justification was revised to correct the ASME Code Class of the valves involved and to clarify which valves can be partial stroke cxercised quarterly.
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E a a FNP.1 M-042 PUMP RELIEF REQUEST PRIO Systom:
Servico Water Pump:
P001 A-A, P001B A, P0010 AB, P0010 B, P00tE.B Class:
3 Functioni Provide cooling water te safety related equipment.
Test Requiromont:
IWP 3400(a) requires that an insorvice test be run on each pump.
Basis for Rollef:
The Sorvice Water System is designed sn that during normal operation there are two pumps in each; the two trains oposining, with a standby pump available to swing to either traln.
Each pump has pressuto gages, however flow instrumentation is installed only to me sure the flow from each of the two trains, Sinco flow instrumentation was not provided during construction for each pump, the only viable means of Individually testing those pumps is by removal of ono pump from service and measuring flow through the train with only one pump aligned However, a flow of 32,18G gpm, which requires four pumps (or both trains operable) is required for normal operation por the FSAR. A condition whero only one pump is aligned at a timo to a train would result in degradod cooling water flow to essential or safety related equipment and is thoroforo an unacceptablo method of operation. Furthermore, removal of one pump from00 service water train could lead to an isolation of the turbine bul':hng service water supply linos causing a plant trip.
Since hydraulic performance of a degrading pump may be masked by the other pump when service water pumps are testod in pairs, FNP has developed analytical methods which can be used to determine individual pump flow rato. Those analytical methods involve solving throo equations involving dual pump flows for threo individual pump flow ratos. Thoso analytical methods have proven rehable in determining individual pump degradation when the other pump in combination is compensating for the degraded pump, Altemato Testingf Quarterly comb 1ned flow, inlet pressure, differential pressure and vibration wUl be measured and compared to reference values. Individual pump ovaluations, which consist of performing three-two pump combination tests at a referenca differential pressure and solving analytical oquations for indMdual flows, will be performed I
whenever combined flow measurements are not in the acceptabfo range and three pumps are available to support the testing. Corrective E0 tion will be taken on the individual pumps as a result of the evaluation in accordance with IWP-3230.
12-31 91 1
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REUEF REQUEST t
01013-RV 1 System:
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- Valvo:
HV 1, HV 2, HV-3, HV-4 Category:
8 Class:
2 Function:
Valves open to vont the reactor vessel.
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. Test Requirements:
Exorciso, timo and fall quarterly. (liW.3411,3413 and 3415)
Remoto position Ltdication- (lkW.3300) i Basis for Rollet:
The head vont valvos can not bo oxorcised during normal operation with adoquate as:urance that an uncontrollod release of roactor coolant and a rapid RCS do-pressurization would not occur. To exorciso the valvos opon in any order could result in a potentia; pressure shock to the closed valvo ard a potential
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reaction. The consequences of this reaction are too sovoro to warrant testing during normat operation.
The RPV head vont valvos are Targot Rock solonold operated valves, The valvo stom is completoly onclosed within the oporator atd thus visusi position verification is impossible. Position indicators (rood switchos) are located within the oporator 1;
and provido poshion indication for the pliot valvo assembly. In ordor to verify that the valvoa oxorciso open and re closo and agroo with remoto indication, it is s
nocessary to establish flow through the vont lines. '~
- cannot be establishod through the vont lines except at refueling of cold shtt dn when plant conditions for testing can be established. To insure that a stuck open valve would not cause i
an uncontrollable loss of reactor coolant and rapid do pressurization it is proforablo that RCS pressuto be less than 100 psig.-
Altortulo Testing:
Those valvos will be full stroke exorcised, timod and fall safo lostod and the head I
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vont flow path verified oporable at refueling or at least overy 18 months as required by the Plant Technical Specifications.' la addition, those valves will be exorcisod at cold shutdownJJ RCS pressuto is loss than 100 psig.
12-31-91 1
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FNP-1 M442 RELIEF REQUEST Q1E21 RV 1 System:
SI/CVCS Valve:
OV026 Category:
C Class:
2 Funcilon:
RWST to charging pump suction line check valve.
ASME Section XI Test Requirements:
Verify forward flow operability quarterly or at cold siedown. (IWV-3521)
Basis for Rollef:
The only possib'e method of full flow testing this valve is by aligning the RWST to the charging pump suctica aled injecting full design flow into the RCS. Full flow tes'ing during nomial operation is impossible because the charging pumps cannot develop full rated flow against RCS pressure.
Patial flow testing cannot be performed during normal operatbn because water fism the RWST is highly borated and injection into the RCS could adverseiy affect reactivity, Full or partial flow testing at cold shutdown could only be performed with a steam bubble in the pressurizer to prevent overpressure transients, However, normal plant practice is to collapse the bubble early in the shutdown procedure and cool the plant down in the solid condition. Therefore, to full or partial flow test at cold shutdown would require maintaining the pressurizer bubble for a longer period of time which would postpone other related shutdown activities.
Alternate Testing:
Design accident flow will be verified to be passing throupa the valve each refueling
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12 31-91
T FNP-1 M 042 RELIEF REQUEST 01 E21-RV-4 System:
SI/CVCS Valve:
Group 1 OV062A, OV0628, OV062C Group < OV066A, OV006B, OV060C Group 3 OV078A, OV0788. OV078C Group 4 - OV079( OV079B, QV079C i
Category:
C Class:
1 Function:
Safety injection to the RCS check valves.
ASME Section XI Test Requirements:
Verify forward flow operability quarterly or at cold shutdown. (IkW-3521)
Basis for Relief:
It is impractical to fu" or part stroke any of these check valves with flow during normal operation because all of the associated flow paths bypass the regenerative heat exchanger and establishing flow through these valves would result in relatively cold water beir'g injected into the RCS. The thermal stresses produced by injecting cold water could greally reduce the service life of the injection nozzles. These valves cannot be full-stroke exercised during cold shutdowns because the RCS may not contain sufficient expansion volume to accommodate the flow required and a low temperature overpressure condition could occur, i
lt is also impractical to confirm a part stroke exercise of these valves during cold shutdowns because permanent flow instrumentation is not installed for the individual flow orifices on the system. The test connections at the oritices have been capped and seal welded. Use of these flow orifices would require a design change to the system.
i Alternate Testing:
One of the valves from each three valve group will be disassembled aM manually full stroke tested at each retuoling on a staggered test basis. The valve intemals will be verified as structurally sound (no Icose or corroded parts) and the disk manually exercised to verify full ?P 2pability, if the disassembled valve is not capable of being full stroke exercs r., r tnere is binding or failure of valve intomals, l
the remaining valves 1. the group must also be disassembled, inspected, and manually full-stroke exorcised 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 desvices.
12-31-91
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FNP.1 M-042 REUEF REQUEST 01E21-RV 6 DELETED (Soo Rollef Roquest 01E21 RV-4) l I
12-31-91 w
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FNP 1 MO42 RELIEF REQUEST 01 E21-RV-10 DELETED (See Reliel Request 01E21-RV-4) 12-31-91
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FNP 1-M442 REUEF REQUEST 01N23-RV 1 System:
Auxiliary Feedwater Valve:
OV006, OV007A. OV007B Category:
C Class:
3 Function:
Condensato storage tank to auxillary feedwater pump suction line check valves.
ASME Section XI Quarterly Test Requirements:
Verify reverse flow closure. (IWV-3521)
Basis for Relief:
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 auxiliary feedwater piping. It cannot be guaranteed that flushing will remove all contamination after testing Any contaminants which remain in the piping may be injected into the steam generators which could adversely affect secondary water chemistry and contribute to steam generator degradation.
Alternate Testing:
Reverse flow c!osure will be confirmed by a leak test. similar to an Appendix J -
Type C Test, during each iefueling outage.
12-31-91
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FNP 1 M442 REUEF REQUEST 01P17-RV 3 System:
Component Cooling Water Valve:
QV087A, OV0878, QV087C
' Category:
C Clans:
3 Function:
- These check valves will close to protect the low pressure component cooling water (CCW) piping from RCP thermal battler leakage, ASME Section XI Quarterly Test Requirements:
Verify reverse-flow closure.(IWV 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 Purnps, entering the containment and locally measuring backflow leakage. Plant procedures strictly regulate entry into the containment during normal operation and at cold shutdown.
Alternate Testing:
During each refueling outage component cooling water flow to the Reactor Coolant Pumps will be isolated and reverse flow closure will be verified by measuring backflow leakage.
12-31 91
FNP 1-M442 RELIEF REQUEST Q1P19 RV 2 System:
Instrument Air Valve:
OV004 Catego<y :
AC Class:
2 Function:
Backup nitrogen supply to pressurizer PORVs.
terly Test Requirements:
Verify forward-flow operability quarterly or at cold shutdown (IWV-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 alt header.
Instrument air supplies a number of components insido containment which are necessary for normal operation. Testing during normal operation or at cold shutdown would deprive these components of their normal alt supply, and since the system has no reserve air storage capacity, could result in operating transients or component failures. Loss of instrument alt 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 components necessary for plant operations.
12-31-91
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FNP.1 M442 REUEF REQUEST 01P19-RV 3 System:
Instrument Air Valve:-
NV135, NV137A, NV137B Category:
C Classi NA Function:
Backup nitrogen supply to pressurizer PORVs.
ASME Section XI Quarter 1y Test Requirements:
Verify reverse-flow closure. (IkW-3521)
Basis for Relief:
There 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 operation or at cold shutdown would
- deprivo these 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:
Reverse-flow closure of these valves will be verificd at refueling when instrument air can be isolated without loss of instruments end components necessary for plant operation.-
12-31-91
FNP 1-M442 I
I COLD SHUTDOWN TEST JUSTIFICATION 01N23-CS-1 System.
Auxillary Foodwater Valve:
QV002 (A through H), OV003, OV006. OV007A, OV0078, OV011 A, OV011B, OV011C Category:
C Class:
3, 2 ASME Section XI Quederly Test Requirements:
Verify forward flow operability. (l\\W 3521)
Cold Shutdown Test Justification:
The only way to verify full forward-flow operabdtty of these valves is by operating the auxiliary 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 large thermal shock to the feodwater nozzles and could cause cracking of the nozzles.
Quarterly Part Stroke Testing:
Valves OV006 and OV007A,B (AFW pump suction check valves) will be partial-forward.f'.ow verified durin0 pump testing-Cold Shutdown Testing:
Full-forward flow operability wl!I be verified by injecting into the steam generators at cold shutdown.
12-31-91
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ATTACHMENT 2
SUMMARY
OF RELIEF REQUESTS TO THE JOSEPH M. FARLEY NUCLEAR PLANT - UNIT 1 INSERVICE TESilNG 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 QlEll-RV-1 PR-2 Q1E13-RV-1 PR-3 QlE13-RV-2 PR-5 Q1E14-RV-1 PR-9 Ql E21-tlV-3 PR-12 QlE21-RV-7 PR-14 Q1G21-RV-1 PR-17 QlN23-RV-2 PR-18 QlPll-RV-1 VG-1 QlP16-RV-2 VG-3 QlPl7-RV-2 VG-4 QlP19-RV-1 QlB13-RV-2 QlR43-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 QlE21-RV-8 PR-6 QlE21-RV-9 PR-8 QlE21-RV-ll PR-15 QlE21-RV-13 PR-16 QlE21-RV-14 PR-19 Q1N12-RV-1 QlEll-RV-2 QlP16-RV-1 Q1 Ell-RV-3 QlP16-RV-3 QlEll-RV-4 QlP16-RV-4 QlE13-RV-3
.QlP16-RV-5 QlE21-RV-2 QlPl7-RV-1 QlE21-RV-5 QlPl7-RV-4 3.
The below listed relief requests have been or will be deleted from the IST Program:
VG-2 Deleted by letter dated October 4, 1989.
PR-7 Deleted by letter dated August 20, 1990.
PR-11 Deleted by letter dated August 20, 1990.
PR-18 Deleted by letter dated July 26, 1991 due to use of Code Case N-472.
QlEll-RV-5 Incorporated into Q1 Ell-RV-3.
QlEll-RV-6 The subject valves are not required to be tested per ASME XI and will be deleted from the program.
Q1E11-RV-7 incorporated into Q1E11-RV-4.
Q1E21-RV-6 incorporated into Q1E21-RV-4, Q1E21-RV-10 Incorporated into Q1E21-RV-4.
Q1E21-RV-11 Incorporated into Q1E21-RV-14.
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